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Item #3: <br />Based on the irrigation data known for the reclaimed irrigated pasture areas from the updated SL-12, <br />irrigation water distribution is as follows: <br />Year IP Reference Area Irrigation IP Reclaimed Area Irrigation <br />2007 7.2 ac-ft/acre 1.47 shares/acre 2.5 ac-ft/acre 0.34 shares/acre <br />2008 7.5 ac-ft/acre 1.47 shares/acre 2.4 ac-ft/acre 0.31 shares/acre <br />The reference area flow rate is calculated from the total share applied to the reference area, and using a <br />gated pipeline scenario that operates 18 hours a day, and 5 days a week. The shares/acre on the <br />reclaimed irrigated pasture are determined from the volume per acre, using sideroll calculations of 20 <br />hours a day, 6 days a week. More detailed walkthroughs of the calculations can be found attached to this <br />letter. <br />The reference area is given more water than the reclaimed area due to the difference in irrigation <br />method. Flood irrigation on the reference area is less efficient than the siderolls used on the reclaimed <br />area. <br />Item #4: <br />Several different questions are posed by DRMS for this item, so they have been isolated for answering <br />specifically. <br />Apparent contradiction of permit text <br />The permit language on page 2.05.4(2)(e)-19D has a paragraph for livestock grazing and another for <br />haying. In the paragraph for livestock grazing, it is stated that "The reference area will be grazed by <br />cows in late June, after any vegetation studies have been completed. The livestock will be removed by <br />the end of June, and the reference area will not be further grazed by livestock during the growing <br />season." <br />Immediately below, the paragraph on Plans for Haying states "The reference area is too small to hay, <br />therefore, it is grazed to simulate the haying. The contractor will be instructed to graze the reference area <br />to the same degree." This statement trumps any previous statements on grazing of the reference area, <br />because the two areas must be managed to the same degree. For example, the 1 st cut on the reclaimed <br />area generally takes place in the latter part of June. The 2nd cut takes place in late July and, in some <br />cases, the 3rd cut takes place near the end of August. The grazing of the reference area in June is meant <br />to simulate the 1 st cut management of the reclaimed area. If WFC pulled the livestock off the reference <br />area at the end of June, there would not be similar management to reflect the second or third cuts of the <br />reclaimed area. Therefore, the grazing that was allowed on the reference area for 2007 and 2008 <br />simulated the 2nd cut of the reclaimed area and is not only allowable, it is necessary. <br />Clarification of statement "unless instructed not to" <br />The language "unless instructed not to" refers to WFC'S procedures of not having farmers graze cattle <br />on areas that have been recently seeded as part of reclamation practices or to not graze areas that do not <br />have sufficient vegetation and need to be protected from over-grazing. Further investigation has <br />determined that there have been no areas within the SL-12 reclaimed irrigated pasture or reference area <br />..r