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C- 1981 -008 MR -118 <br />Preliminary Adequacy Review <br />23 August 2011 <br />Page 3 of 3 <br />permit must be revised to address the expected rates of irrigation application for ALL lands, both <br />east and west of 2700 Road. <br />Commitments regarding fertilization of the Irrigated Pastureland and the IP reference area have <br />also been found to be contradictory within the permit. The last sentence on page 30 of Section <br />2.05.4(2)(e) states, "Fertilizer may not be applied every year. It will be applied at the frequency <br />that is normal good practice for the area and the soils, as determined by NRCS." Subsection <br />4.6.1, beginning on page 37, reads as follows: "Beyond the first year of the liability period, <br />nitrogen and phosphorus will be applied to the Reclaimed Irrigated Pastureland areas and the <br />reference area at the following rates annually: Nitrogen: 60 lbs /acre; Phosphorus: 20 lbs /acre. <br />These rates are those recommended by the local NRCS office in Norwood, CO." <br />The second paragraph of Subsection 4.6, as approved with PR -06, states that, "However irrigated <br />pastureland will not use a sideroll; all irrigation is flood on IP." This statement is in error, in that <br />it appears that all discussion of reclaimed areas east of 2700 Road has been removed from the <br />permit. This section needs to be revised to address reclamation management for all Irrigated <br />Pastureland areas within the permit area. <br />A number of these additional items are of sufficient magnitude that a Technical Revision to the <br />permit will be required in order to accomplish the necessary changes. <br />Please contact me at your earliest convenience to discuss MR -81 and the pending Technical <br />Revision application. <br />Sincerely, <br />Marcia L. Talvitie, P.E. <br />Environmental Protection Specialist <br />cc: Sandra Brown, DRMS <br />