2011-08-04_ENFORCEMENT - C1981008 (4)

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This (8,523 lb /acre) is equivalent to 4.26 tons /acre. OSM assumes this is the basis for the conclusion on page 2.05.4(2)(e) -45 of the permit previously referenced which states, "The yield ranged from a high of 4.26 tons /acre for highly managed alfalfa..." This is repeated again on page 2.04.10 -61 of the permit which states, "the Alfalfa field which was intensively managed produced the highest yields (8523 lbs /acre)," and this data is also shown in Table 2.04.10 -18 — "Permit studies conducted in 1999." OSM again notes this is a first cutting only yield. Examination of Exhibit 2.04.10 -1 of the permit indicates that field 1 referenced above consists of predominately 98E - Darvey -Barx Complex Prime Farmland soils with a small amount of • 98D - Bowbac- Bowdish Complex soils $' OSM also notes that the permit does state 1999 was an above average precipitation year. Such climatic factors notwithstanding, both the soils and highly managed irrigated alfalfa yields indicate, at a minimum, that a first cutting yield of 1.84 tons /ac may be an underestimate of yield for irrigated alfalfa on this particular prime farmland. It appears the data (in bold for easier reference) presented above is based on prime or prime - like soils having a very similar yield for irrigated alfalfa according to the NRCS. It also appears the actual first cutting yields for irrigated alfalfa grown on "Field 1" of the Morgan property referenced in section 2.04.10, subsection 6.3 best matches the requirements of Colorado Rule 2.06.6(2)(g) which reads in part, "Each plan shall contain, at a minimum: the productivity under high level of management..." which is addressed in permit section 2.05.4(2)(e) which states Irrigated Cropland, "areas will have 100% alfalfa (not including a companion crop) which are well - managed, irrigated consistently and harvested." In sum, the estimated yield based on soils as well as the actual first cut irrigated alfalfa yield from "Field 1" noted above compare reasonably well with the NRCS 4 April 2011 yield estimates, and would seem to be the best information presented in the permit on which to base a yield standard for irrigated alfalfa on prime farmland, and particularly for the Morgan property as this is where this data appears to come from. However, OSM's review was unable to determine that this information was used in constructing the 1.84 tons /ac first cutting yield standard in the permit. Section 2.04.10, subsection 6.3 continues, "The second Morgan hayland field of 28 acres is a mixture of grasses and forbs with approximately 10 to 15 percent alfalfa. The field was not irrigated this year and white tail prairie dogs have invaded about 1/8 of the field. Further cattle grazed the field from late winter into the growing season. Morgan was going to renovate the field but did not have the time this year. Morgan mowed and baled the field to reduce annual weeds and allow for future operations. The field yielded 394 bales on first cutting with an average bale weight of 81 lb/bale. The production for this field was 31,914 pounds (394 bales X 81 lb/bale) or 1,140 lb /acre. The third field on the Morgan property was a small sub irrigated 1 acre parcel of grass and forbs. The field yielded 21 bales on first cutting with an average bale weight of 87 lb/bale. The production for this field was 1,827 pounds (21 bales X 87 lb/bale) or 1,827 lb /acre. " Following this, page 2.04.10- 61(still in section 2.04.10 -6.3 of the permit) states, "Morgan plans a second cutting of alfalfa. Neither Johnson or Morgan plan a second cutting of their grass hay and 13