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expansion area in 1998. Although Barx soils were identified (unit 98E on Map 2.04.9 -1), IRI <br />concluded, based on the Important Farmland Inventory criteria as modified for Colorado, that <br />Barx soil was not considered as being prime farmland because the pH was higher than 7.4 in all <br />horizons. <br />Early in 2008, the USDA NRCS provided the Division with updated information regarding the <br />subject of prime farmlands and the New Horizon Mine. In a letter written February 11, 2008 <br />(Attachment 2.04.9 -6), a Soil Scientist explained that the limiting pH threshold of 7.4 found in <br />the CIFI was in error, and should have been 8.4. Additionally, the CIFI has since been rendered <br />obsolete, and determinations for Prime Farmland are based on the national criteria as described <br />in the National Soil Survey Handbook — 7 CFR Ch. VI Part 657, Subsection 657.5, dated Jan. 1, <br />2000 (Attachment 2.04.9 -6). The letter concludes that both Darvey and Barx soils mapped in the <br />1998 IRI survey are considered Prime Farmland. <br />In a letter dated February 21, 2008 (Attachment 2.04.9 -6), the Resource Conservationist from the <br />Norwood office of the NRCS provided a positive determination of prime farmland for Begay <br />Fine Sandy Loam, 1 to 3 percent slopes (map unit 98A) on the WFC property in the far <br />northwest corner of the permit area. A smaller area of Begay (98A) soil on the Lloyd property <br />was not considered to be prime farmland. <br />The 1998 survey by IRI identified Darvey -Barx complex (98E) soils in three separate areas, as <br />shown on Map 2.04.9 -1: 1) approximately 5.8 acres straddling 2700 Road, immediately south of <br />Tuttle Draw; 2) approximately 17 acres on the Benson parcel north of BB Road and east of 2700 <br />Road; and 3) approximately 87 acres on the Morgan parcel south of BB Road and west of 2700 <br />Road. In a letter dated June 27, 2008 (Attachment 2.04.9 -6), the NRCS determined that the 5.8 <br />acre area was not considered prime farmland because historically, these areas were not managed <br />as cropland and lacked sufficient water for irrigation. The Morgan property acreage was <br />confirmed to be prime farmland. The 17 acres on the Benson parcel was not evaluated, as it had <br />previously been mined and reclaimed. <br />The NRCS positive determination in February 2008 for prime farmlands caused the Division to <br />require that WFC immediately revise the permit to address soil handling and management <br />practices. This was accomplished with Technical Revision No. 57 (TR -57). Topsoil salvage and <br />management plans are discussed in Section IV of this document. The revegetation methods and <br />plans for the prime farmlands are addressed in PR -6 and discussed in Section VII of this <br />document. All prime farmland requirements are addressed in Section 2.06.6 of the permit and in <br />Section XVIII of this findings document. <br />F. Vegetation and Land Use <br />The natural vegetation in the Nucla area was pinyon - juniper woodland and Great Basin <br />sagebrush. More than 100 years of intensive agricultural activity in the area has resulted in only <br />scattered remnants of the native vegetation types. Prior to the agricultural conversion, sagebrush <br />shrublands occupied the park -like areas with deeper soils and more gentle slopes while the more <br />broken upland areas with shallow coarse textured soils were occupied by the pinyon - juniper <br />woodlands. <br />I: <br />