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Section 2.04.10 subsection 5.6 of the permit goes on to note the cropland in the western portion has <br />been managed without a specific yield goal nor yield data by Mr. Morgan for about 20 years; and that <br />the land was fallowed in 1987. It continues, "The Agricultural Stabilization and Conservation <br />Service ASCS office in Montrose Colorado has no historic farm based yield numbers for the cropland <br />fields within the permit area (personal communication ASCS office August 1988)." <br />There are estimated yields of barley and winter wheat reported by Mr. Morgan as well as Mr. <br />Weimer. It continues, "An estimate of potential grass hay production may be gained from evaluation <br />of the hay fields just north of the cropland areas within the permit area... These hay fields have <br />similar site conditions and soils as the cropland areas, the majority being mostly Progresso complex <br />soils Map Unit 30C. The hayland north of the cropland in the permit area is dominated by grasses. <br />Table 2 -5 in Attachment 2.04.10 -6 formerly Peabody Appendix 10 -2, shows estimated hay yields for <br />these fields to be 1,168 pounds /acre. " <br />It appears the following permit conclusions lack scientific rigor: "Since soils and site conditions <br />are identical for the two areas, this yield must be the potential for the areas identified as cropland <br />within the permit area. Therefore baseline information may be assumed to be similar for the two <br />areas." In sum, the reference crop for the Morgan property is alfalfa and having a high level of <br />management, including irrigation; yet the permit language above is discussing `grass hay;' with <br />no apparent discussion of irrigation availability nor practice. Further, the referenced language <br />contrasts with the previous permit statements of expected yields based on soils. <br />Subsection 6.3 in Section 2.04.10, starting on page 2.04.10 -59 —1999 Baseline "Irrigated Pasture — <br />Hayland Type (IPH)," starts off by noting, "Since this description was originally written by IRI in <br />1999, the Morgan fields east of the fenceline in the southwest portion of the 1999 study area have <br />been reclassified as Irrigated Cropland (IC). Therefore, the discussion and tables for this vegetation <br />type include some Morgan fields which are Irrigated Cropland (IC) and some Irrigated Pasture <br />Hayland f elds (IPH). The original narrative which has not been changed is included below." This <br />section continues, "these fields generally occur on soil map units 98D (Bowbac - Bowdish complex) <br />and 98E" (Darvey -Barx complex). <br />Subsection 6.3 in Section 2.04.10 continues: <br />"The Morgan property has three hayland fields. The first field of 21 acres is currently raising <br />alfalfa. The field has been furrowed and is supplied water via gated irrigation pipe. Morgan <br />manages the alfalfa by plowing it up every 5 to 7 years. The field is disked and furrowed. The field is <br />then fertilized and planted to alfalfa. Each year the furrows are cleaned to insure the proper flow of <br />irrigation water. The field yielded 2,034 bales on first cutting in 1999 with an average bale weight <br />of 88 lbs/bale. The production for this field was 178,992 pounds (2,034 bales X 88 lbs/bale) or <br />8,523 lb /acre. " <br />6 4 April 2011 NRCS letter to OSM signed by Mr. Steve Park, State Soil Scientist, states, the 98D Bowbac - Bowdish complex 0 to 3 percent slope most <br />closely resembles map unit 80 —Progresso loam, 1 to 2 percent slopes in the San Miguel SSA with an estimated yield of 5.5 tons /ac irrigated alfalfa hay. <br />9 4 April 2011 NRCS letter to OSM signed by Mr. Steve Park, State Soil Scientist states, the 98E Darvey -Barx Complex 0 to 3 percent slope most closely <br />resembles map unit 14 —Bari fine sandy loam, 1 to 3 percent slopes in the San Miguel SSA with an estimated yield of 5.5 tons/ac irrigated alfalfa hay. <br />irrigated alfalfa hay. <br />12 <br />