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2011-05-05_REVISION - C1981008
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2011-05-05_REVISION - C1981008
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Last modified
8/24/2016 4:33:19 PM
Creation date
5/6/2011 1:49:38 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
5/5/2011
Doc Name
Adequacy Review No. 4 Letter
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
SL12
Email Name
MLT
SB1
Media Type
D
Archive
No
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C-1981-008 - SL-12 <br />Adequacy Review No. 4 <br />5 May 2011 <br />Page 8 of 10 <br />terms. However, since TR-58 was not approved until May 13, 2009, and the sampling was conducted in <br />2007 and 2008, the management activities following TR-58 approval are not relevant to this bond release <br />application. With the approval of TR-58, the following items will be necessary for future bond release <br />applications. <br />a) With the approval of TR-58, WFC committed to apply irrigation water to the reclaimed areas and the <br />reference area at the same time and to release water to both areas at the same time. WFC must provide <br />the dates irrigation water was applied to both the reference area and the reclaimed areas. <br />b) WFC also commits to use 10 shares of water to irrigate the reference area which is applied through the <br />CCC ditch. The approved plan says, "the reclaimed area will receive approximately I share per acre if <br />a side roll is used. If flood irrigation is used, the same application rate as the reference area is used, <br />which is 1.64 shares per acre. " <br />The application rates on both the reference and the reclaimed areas must be documented. <br />c) Plans for Grazing. The approved plan says the "reference areas will be grazed by cows in late June, <br />after any vegetation studies are completed. The livestock will be removed by the end of June, and the <br />reference area will not be further grazed by livestock during the growing season. The reclaimed area <br />will be hayed in late June after any vegetation studies are completed. Winter grazing by cows, deer and <br />elk occur on all areas ". For both the reference area and the reclaimed area, the number and type of <br />grazing animals is needed as well as the specific dates of grazing. <br />d) Plans for Haying. The approved plan says, "The reclaimed area is hayed in late June after any <br />vegetation studies are completed. The reference area is too small to hay, therefore, it is grazed to <br />simulate the haying. The contractor will be instructed to graze the reference area to this same degree. " <br />Future bond release applications must address any haying activities or explain that haying was not <br />conducted. <br />10. Please provide cover summary tables, to supplement the spreadsheet Tables Al and A2, in the data section <br />of the Vegetation Report (refer to Item 3, above, for detailed explanation of the request). <br />Summary tables were included with the Aug. 2010 response. Item resolved. <br />11. 2007 IP production success demonstration is presented on pages 11 and 12 of the Phase 3 Vegetation Report. <br />Summary information including statistics is presented in Table 2, page 11. Sample Data is presented in <br />Table A3 (reference area) and Table A4 (reclaimed area). The reclaimed area production sample mean <br />exceeded the reference area sample mean by a wide margin, and because sample adequacy was not <br />demonstrated in the reference area, a 2-sample reverse null t-test was properly selected to demonstrate that <br />the difference was statistically significant (i.e. that the reclaimed area true mean exceeds the reference area <br />true mean). The various formulas associated with the t-test demonstration are presented in their correct and <br />proper form in equations 4, 5, and 6, on pages 8 and 9 of the report. <br />In the calculations however, there were a couple errors, one minor, and one more significant. <br />a) In Table 2, the Table t-statistic used for comparison to the calculated t-statistic is the t value for an alpha <br />error probability of 0.1. This value is more stringent than the alpha error probability level of 0.2 <br />allowed by Rule 4.15.11(2)(c), and specified in Equation 6, on page 9 of the Vegetation Report. This is <br />a minor error, which would work to the disadvantage of the operator. <br />b) The more significant error is that, apparently, a parenthesis was inadvertently omitted from the t-test <br />formula of Equation 6 when it was entered into Excel as a formula. This resulted in an erroneously high <br />value for the calculated t-statistic (3,705.304), as reported in Table 2. The Division independently <br />entered the data and ran the statistical tests for the 2007 IP production data in Excel, with the <br />spreadsheet data . Our results are presented in Attachment 2 to this memorandum. The calculated t- <br />statistic we obtained was 4.7. Since 4.7 is greater than the table t-statistic of 0.847 (for alpha error
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