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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
Metadata
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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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The seeding methodology description presented in the next to last paragraph of amended <br />Subsection 5.4, still mentions "species of grass" in reference to the seeding. Alfalfa is the <br />crop species planted in Seedmix 7, and the green manure crop includes yellow sweetclover, <br />neither of which is a grass. The reference should be simply to "planted species" rather than <br />"species of grass ". Much of the detail that was deleted from the previous version of the <br />paragraph including use of either a cultipacker or drill seeder (with specific capabilities) was <br />appropriate, and should be restored, unless appropriate explanation is provided. Unless <br />broadcast seeding would be employed for use on cropland Seedmix 7 or the green manure <br />crop, the reference to use of broadcast seeding should deleted. Broadcast seeding does not <br />provide "the greatest level of success in terms of proper seed placement and firming of the <br />soil around the seed". If broadcast seeding is retained, please confirm NRCS and landowner <br />concurrence, and address measures that would be used to cover the seed. <br />"Species of grass" changed to "species ". <br />Cultipacker was removed as a seeding device at the request of the landowner. <br />According to the Morgan's, who have been farming in the area for many decades, <br />cultipackers are not available in that area. A spring tooth harrow or similar device will <br />be used if broadcast seeding takes place. <br />vi. The Division requested modifications to the "Quality Standard" for irrigated cropland in <br />Subsection 5.5.2, and the subsection was updated as requested. However, we request one <br />minor modification. In the first sentence of the "Quality Standard" description, please <br />replace county listed noxious weeds with permit listed noxious weeds, for consistency <br />with other permit sections. <br />Noxious weeds language has been changed to match DRMS required text. <br />vii. The Division requested a minor clarification to narrative in Subsection 5.5.3 to clarify <br />sample adequacy requirements with respect to small bale "in field" measurements. <br />Resolved. <br />viii. The Division requested clarification to narrative in Subsection 5.5.3 to clarify sample <br />adequacy requirements with respect to large bale truck scale measurements. Resolved. <br />ix. The Division requested revision of narrative in Subsection 5.5.4 to comply with the time <br />frame requirements of Rule 4.25.5(3)(a). As the Division pointed out, the rule provision <br />specifies that crop production be determined based upon a minimum of 3 years of data, <br />and that crop production be measured for the three cropping years immediately prior to <br />bond release. The narrative as revised by WFC does not specify that the multiple years <br />of data used to determine the average crop production would include the three cropping <br />years immediately prior to full release of bond. Please revise the narrative of Subsection <br />5.5.4 to specify that calculation of the average crop production value used for <br />demonstration of crop production success would include the crop production values <br />determined for the three cropping years immediately prior to bond release, <br />The text of subsection 5.5.4 has been modified to emphasize that the multiple years <br />of data used to determine the average crop production will include the three years <br />immediately prior to the bond release application. <br />
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