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is appreciably lower than the 5.37 tons /acre annual yield potential expected for the <br />Morgan property; and, therefore would represent a significant underestimation of <br />what the reclaimed prime farmlands should ultimately be demonstrated to achieve as <br />having restored yield capability. <br />An accurate, measure of the annual yield for an irrigated alfalfa crop in any given year is to gain this <br />value through summing all cuttings for the individual growing season. In additional to being a <br />regulatory requirement, annual production measurement is a standard practice shared among many <br />experts and is reaffirmed in the technical literature addressing this specific subject (irrigated alfalfa <br />fields). <br />OSM's review finds that the revegetation yield standard included within the permit has not <br />been derived in a manner that is technically or scientifically supportable, and is therefore not <br />in accord with the requirements of either Rule 2.06.6 or Rule 4.25.5. <br />REVIEW PREPARED BY: <br />Alex Birchfield <br />Ecologist <br />Rick Williamson <br />Ecologist and Technical Team Leader <br />Date: 7 <br />9 <br />Date: 2 <br />