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2010-11-10_REVISION - C1981008 (3)
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2010-11-10_REVISION - C1981008 (3)
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Last modified
8/24/2016 4:26:41 PM
Creation date
11/10/2010 3:11:20 PM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
11/10/2010
Doc Name
List of Exhibits and Witnesses and Exhibits
From
Carver Schwarz McNab & Bailey, LLC
To
DRMS
Type & Sequence
PR6
Email Name
SB1
DTM
MLT
Media Type
D
Archive
No
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sample mean. Current standards are reflective of expected total field harvest of baled hay. <br />It is possible that the production results obtained from the clipped plot method might vary <br />considerably from the results obtained from the total field harvest method. If so, it would <br />be appropriate that the standard be adjusted, in cases where success comparison for <br />irrigated pasture or cropland would be based on clipped plot mean. The extent to which <br />results of the methods vary could be established by statistically adequate sampling of one <br />or more fields, followed by swathing, baling, and total harvest weight determination, in <br />accordance with procedures specified in the application, for the same field(s). Please <br />commit So conduct a comparison test to establish- the relationship between p"ducfion <br />sampling and total field harvest results, and to submit the results of such comparison <br />within the 20@7 Annual Reclamation Report, to allow for assessment of the seed to <br />adjust the success standard in the event that clipped plot sampling i used for bond <br />release demonstration. <br />26. There appear to be two lists of Attachments in the Table of Contents for Section 2.04.10; <br />the first list appears to be incorrect, and should be deleted. The second, longer list, appears <br />to correspond to the attachments included in the section. However, we question why <br />Attachment 2.04.10.9 ("Old Peabody Attachment 9-5", which is baseline soils <br />information), and Attachment 2.04.10-10 ("Old Peabody Addendum 11-1", which is <br />wildlife baseline information) would be included in Section 2.04. 10 (Vegetation <br />Information), rather than in Soils Information and Wildlife Ittforination sections of the <br />application, respectively. Please address these apparent discrepaiscies, and awed the <br />sections as appropriate. <br />27. Clarification is requested regarding the plan for 2"4 growing season and "mid liability <br />period" vegetation monitoring as described beginning on page 2.05.4(2)(e)-39. Methods <br />and intensity of monitoring intended is not clear. There is one statement indicating that <br />methods may be diffacnt from baseline and bond release sampling, and another statement <br />that "statistical adequacy will be demonstrated so the information could be utilized for the <br />various phases of bond release...". Please revise the referenced section to clarify the <br />mature and intensity of "non-bond release" monitoring to be conducted. <br />28. We note that the June 24, letter from Dean Stindt (then with NRCS) has been deleted <br />from the amended application. In the event that proposed technical standards for irrigated <br />hay cropland (1.84 tons/acre) and irrigated pastum west of 2700 road (1.5 tons/acre) are <br />retained, it would be appropriate that the subject letter be included in the application as <br />supporting documentation. Phase provide a copy of the June 24, IM letter from Dean <br />Stin& for inclusion in amended Attaclmewt 2.05.4(2ue)-3. <br />. WFC Exhib'y 2 <br />Page 11 of ti
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