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2010-09-22_REVISION - C1981008
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2010-09-22_REVISION - C1981008
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Last modified
8/24/2016 4:23:20 PM
Creation date
9/22/2010 5:00:56 PM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
9/22/2010
Doc Name
Response to Adequacy No. 5
From
Greg Lewicki & Associates
To
DRMS
Type & Sequence
PR6
Email Name
MLT
SB1
Media Type
D
Archive
No
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Language has been added to subsection 4.6 discussing the irrigation sequence. Since <br />it is so similar to irrigation management for IC, just without the siderolls, the <br />detailed discussion in subsection 5.7.4 is now referred to. <br />Subsection 5.0 Reveectation - Irrieated Cropland (ICI. <br />The Division notes there were quite a few changes to the seedbed preparation, seeding and time frames <br />for Morgan prime farmland that were not prompted by our adequacy comments. Some of those changes <br />may have been requested by the landowners, but that is not clear. That section had previously been <br />close to approval, but now it is full of conflicting information and vague language. This type of <br />submittal creates undue delays in our review. In the future, the Division requests that W FC explain and <br />identify in the cover letter any changes that have been made beyond what is requested in the adequacy <br />letter. Furthermore, if WFC is proposing changes to one section, it is imperative that those changes <br />remain consistent with narrative in other sections of the permit. Please cross -check to ensure <br />consistency in the application. <br />e. Subsection 5.2 addresses irrigation designs for the Morgan property. <br />i. A typographical error was corrected. Resolved. <br />ii. Map 2.05.4 -5 field labels and boundary lines were modified as requested. <br />Resolved. <br />iii. Map 2.05.4 -5 was revised to depict gated pipeline locations. Resolved. <br />f. The first paragraph of Subsection 5.3 was reworded to delete outdated references, as <br />requested. Resolved. <br />g. (i through v) <br />In this item, the Division had numerous questions regarding seeding procedures and seeding <br />rates, and conflicting information regarding such in various subsections. Information in <br />Subsections 5.3, 5.4, and 5.7 was revised, in part to address the Division's questions, and <br />apparently also in part to incorporate landowner requests. Inconsistencies remain and we <br />have a number of questions and requests. <br />There is confusion regarding the timing of various seedings. In Subsection 5.3, narrative <br />indicates that Mix 7 (alfalfa plus companion crop) would be applied in the fall of Years I and <br />7, with initial seeding of green manure crop in spring of Year 1. Subsection 5.4 indicates <br />Mix 7 would be seeded in June, and green manure crop would be planted "prior to August <br />21". In Subsection 5.7, green manure crop would be seeded in spring of Year 1, and would <br />be plowed up prior to planting of Mix 7 "around August ". To eliminate this confusion, <br />please consolidate all seeding timeframe specifications in Subsection 5.7.1, with planting <br />dates for particular seedmixes listed only one time. Replace generalized references such as <br />spring, fall, or "around August ", with specified calendar windows (in accordance with NRCS <br />recommendations and landowner requests). <br />In order to clarify seeding times, the entire schedule is consolidated into subsection <br />5.7.1. All other subsections refer to this when discussing seeding times. <br />There is also confusion regarding seedmix and rates for the green manure crop and <br />companion crop. In Subsection 5.3, it is stated that the green manure crop would be oats at <br />75 # /ac or Quickguwd at 20# per acre, along with yellow sweetclover at 2# per acre. Would <br />Quickguard at 20# per acre be expected to provide the same quantity of green manure <br />
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