2013-03-08_REVISION - C1981008 - Laserfiche WebLink

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Page 2 of 9 and management activities that occurred on the Reclaimed Irrigated Pasture areas and the Irrigated Pasture Reference Area for each year from 2003 to 2012. Grazing In general, the grazing practices for the Irrigated Pasture Reclaimed Areas do not seem proportional to the grazing practices in the Irrigated Pasture Reference Areas, nor do these areas appear to have been grazed at the same time. In the future, the applicant needs to clarify the grazing practices and make a clear comparison using equivalent units between what occurred on the reclaimed areas and the associated reference areas for the years sampled for revegetation success for a bond release application. It does not appear the applicant kept grazing records for the Irrigated Pasture Reclaimed Areas and Reference Areas until 2010. For the years 2008 and 2009, the applicant indicates grazing did occur on these sites but no specific information about stocking rate and grazing periods were discussed for the Reclaimed Areas. The applicant states that grazing was "similar to that described in 2010 and 2011 for the Pasture Reclaimed Areas." The applicant indicated that two to seven horses grazed Irrigated Pasture Reference Area starting in July of both 2008 and 2009 and continued until the spring of the following year. Also the 2007 management practices section of the application indicated two to seven horses grazed the Irrigated Pasture Reference Area from July of 2007 to the spring of 2008. The Division could not verify these statements with the annual reclamation reports for these years for the Irrigated Pasture Reference Area. Given the unknown and undocumented grazing practices of the Irrigated Pasture Reclaimed Area and the supposed and undocumented grazing practices of the Irrigated Pasture Reference Area, the Division cannot affirmatively find that the applicant has complied with the commitments in the permit and the requirement of Rule 4.15.7 (3)(f) that the Irrigated Reclaimed and Reference areas were managed the same for the years they were sampled for bond release. As a result, the 2008 and 2009 revegetation monitoring reports cannot be used to determine revegetation success. The record keeping in regards to the management histories for 2010, 2011 and 2012 contain more detailed information. However the grazing practices on the Irrigated Pasture Reclaimed Areas for 2011 and 2010 are difficult to compare to the grazing practices conducted on the Reference Area for these years. The grazing practices do not seem to be proportional in terms of stocking rate or equivalent in terms of duration as described above. The annual reclamation reports for these years give the Division a better indication of when these areas were grazed and the stocking rate is reported but the information is still not adequate for a clear comparison between the two areas. Irrigation In regards to irrigation practices, page 30 of section 2.05.4(2)(e) of the permit indicates that water will be applied to the Irrigated Pasture Reclaimed and Reference areas at the same time. This does not always appear to be the case based on the information supplied in the SL14 bond release application. In general, the irrigation was started and stopped on these areas within a few days of each other, however in 2010 for example, the Irrigated Pasture Reference Area was irrigated starting April 19, but the Irrigated Pasture Reclaimed Area was irrigated starting on May Stn Fertilization Fertilizing practices do not appear to be consistent with the permit. Page 37 of section 2.05.4(2)(e) states, "Beyond the first year of the liability period, nitrogen and phosphorus will be applied to the Reclaimed Irrigated Pastureland areas and the reference area at the following rates annually: Nitrogen: 60 lbs /acre Phosphorus: 20 lbs /acre"