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12. DRMS consulted with NRCS to determine that PR -6 would meet <br />prime farmland regulations, including 2 CCR 407 -2 Rule 4.25, which is the rule <br />that governs topsoil management on prime farmland. R. 7371:1- 7372:5; Proposed <br />Decision and Findings of Compliance, R. 7818, 8th and 9th paragraphs. <br />13. The Morgans requested that all of their property be reclaimed as <br />irrigated cropland, so Western Fuels - Colorado purchased additional shares of <br />water from the Morgans to meet NRCS water requirements for irrigated cropland. <br />R. 7316:20 - 7318:1, 7379:23- 7380:1; Proposed Decision and Findings of <br />Compliance, R. 7818, last paragraph (requiring the Morgan property to be <br />reclaimed as irrigated cropland). <br />14. The final, approved version of PR -6 provided that the productivity <br />standard by which reclamation success would be determined was a set amount, <br />1.84 tons per acre on the first cut. R. 7372:1 -5; 7414:2 - 7415:3. DRMS and <br />NRCS believe that this productivity standard can be achieved. R. 7373:7 -22. <br />15. At the Morgans' request, the specifications for equipment to be used <br />when preparing the soil for planting were changed to equipment the Morgans <br />already had on hand. R. 7376:13 -23. <br />16. The Morgans used side rolls to irrigate some of their property <br />beginning in 1996. R. 7336:23 -25. The irrigation plan in PR -6 incorporates the <br />;00145923 2 1 8 <br />