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neither property owner remember previous year's yields as both indicated they get what they get and <br />stack it up." <br />"Composition of the irrigated pasture hayland type is highly variable from field to field. Fields <br />generally in good condition are dominated by orchard grass, smooth brome, alfalfa and clover. <br />Areas that have poor drainage are dominated with rushes and sedges. Areas in less than good <br />conditions are dominated with Kentucky bluegrass and various weeds." <br />"Morgan, Johnson and Benson all thought that they could achieve an annual production potential <br />of 3 tons/acre in two cuttings as was asserted by operators in 1987 and .reiterated in 1999. <br />OSM notes that in a 22 March 2011 fax received from MS. Turner, she took exception to this . <br />statement, writing, "Ross Gubka came to us and asked us if we would write a letter to lower our <br />production rates or they couldn't get bond release. We usually have 5 + ton per year." <br />The permit continues, "Since Johnson was the only person to both irrigate and harvest his two first <br />cutting fields of 2.2 and 1.97 tons /acre are within the 1987 assumptions of area operators. These <br />figures are higher than those shown in table 2.04.10 -8 which indicates an average 1932 lbs /acre (97 <br />tons /acre in 1987). Variation in yield in 1999 was directly related to the degree of management and <br />climatic variability. The Alfalfa field which was intensively managedproduced the highest yields <br />(8523 lbs /acre) (OSM again notes this appears to be a yield number from the first cutting only) <br />while the least managed field that had been invaded by prairie dogs had the lowest yield (1140 <br />Ibs /acre). <br />"A dominant factor contributing to production values in 1999 is the climatic trend for 1998 -1999. <br />1999 is thus far proving to be an excellent year for herbage production. The 1998 -1999 winter was <br />warm and mild (table 2.04.10 -2) and the precipitation for spring and summer has been high (Table <br />2.04.10 -1). Precipitation is running 177 percent of normal for the San Miguel Basin (NRCS, NOAA). <br />This trend has had the effect of elevating production levels." <br />Data taken in 1999 from Table 2.04.10 -18, "First Cut Hay Production lbs /ac For The Various <br />Operators Utilizing The Irrigated Pasture Hayland Type (IPH) New Horizon 2 Permit Expansion <br />Study Area 1999" shows the following for 3 fields on the Morgan Property. A disclaimer at the <br />bottom of the table in the permit states, "Reader should be aware that the nomenclature of Morgan <br />Field 1, 2 & 3 plus Johnson Field 1 & 2 in Table 2.04.10 -18 are unique to this Table only and should <br />not be confused with Field names listed on other maps text in other Sections. For a none (sic) scaled <br />location of these fields please refer to the following Exhibit (Table 2.04.10 -18) on next page. " <br />The inclusion of such disclaimers and the discussions of the Morgan property covered in both <br />the Irrigated Pasture Hayland and the Irrigated Cropland sections, as cited above, adds <br />unnecessary confusion. Upon designation of the Morgan property as Prime Farmland, all <br />information on Prime Farmland would have better been consolidated into the appropriate <br />section (Irrigated Cropland) during the revision process; and quality control and assurance <br />measures taken to avoid such disclaimers and unnecessary confusion where ever possible. <br />14 <br />