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>> to eliminate the requirement to include success standards and measurement <br />> > techniques in the approved reg3-61atory program be retaa.ned? <br />>> Answer: It is anticipated that the final federal revegetation rules will <br />» be publshe in u3y, 206. 616.116(a)(1) will be amended and will no <br />>> longer require that success standards and measurement techniques be <br />>> included in regulations subject to OSM approval. However, the final rule <br />>> will differ from the proposed rule. The final rule will include some <br />>> type <br />>> of provision requiring that state regulatory authorities maintain a <br />>> listing of acceptable success standards and measurement techniques, <br />>> within <br />>> guidelines or comparable documents, that are available to the public and <br />subject to public review and comment. <br />I also mentioned to Bob the difficulty of developing a sound technical <br />>> standard, due to the lack of published NRCS production information for <br />>> several of the soil types that are irrigated locally, as well as the fact <br />>> that representative dryland pasture is a scarce commodity, and there are <br />no applicable published production figures. <br />>> Bob's recommendation was that, if at all possible, WFC should attempt to <br />>> use reference areas for irrigated pasture and irrigated hayland, as well <br />>> as dryland pasture and rangeland. I explained some of the difficulties <br />the operator was experiencing with reference areas and he understood some <br />>> of the problems. But he reiterated that his recommendation would be that <br />>> the operator look far and wide for reference sites that would work, even <br />>> if it required lease agreements or similar arrangements with area farmers <br />>> or the BLM. Another option we discussed, was that maybe the historic <br />>> record approach would be applicable for irrigated pasturelands and <br />>> irrigated haylands. This would entail a minimum of probably 5 years of <br />>> production records or statistically adequate sampling from applicable <br />>> fields. If there are existing records available from NRCS, FSA, or other <br />>> agencies, or individual farmers, for particular lands that can be tied to <br />>> the soil types of concern, this might be a workable approach. If such <br />>> records are not available, possibly suitable fields could be located and <br />>> WFC could collect the data annually for 5 years to "build" the technical <br />standard. <br />>> From a regulatory perspective, Bob is no doubt right, that use of <br />>> reference areas and/or historic record data would be cleaner and <br />preferable. Although the federal rule requiring OSM approval of a <br />>> program <br />>> amendment for technical standard wil apparently go away in the near <br />>> future, the Division will apparently still be required to develop <br />>> "programmatic" type approaches or documents for use as technical <br />>> standards, which would likely entail a lengthy time period for <br />>> development, including public review and comment periods. <br />>> By the way, when the original standards for irrigated hayland and <br />irrigated pastureland were developed back in the day, OSM approval was <br />>> apparently not obtained, and when the standards were amended in 2000, the <br />>> OSM approval requirement was also overlooked (that was my bad; I was <br />>> involved in that review). <br />>> Anyway, let me know what you think. I think we shoud take Bob's input <br />into consideration and discuss it with Greg Lewicki at our meeting on <br />2