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permit revision request, PR Number 7, with DRMS. PR7 seeks a revision of <br />previous prime farmland determinations, soil redistribution, and vegetation plans. <br />That application is under review by DRMS, and there remains a question as to <br />whether it will render PR6 moot, or whether PR 7 is essentially an attempt to roll <br />back previously enacted prime farmland protections. <br />The Record also reflects that the federal Office of Surface Mining (OSM), <br />which exercises oversight of DRMS pursuant to the federal Surface Mining <br />Control and Reclamation Act, engaged in a technical review of PR6 and found <br />significant deficiencies in the conclusions reached by DRMS and the Board— <br />including specific findings that aspects of PR6 do not comply with the state <br />regulatory program. Those defects resulted in an order that WFC engaged in a soil <br />sampling and analysis program, which was implemented in late 2011. <br />The Morgans do not disagree with parts of PR6, specifically the designation <br />of all of the Morgan Property as containing prime farmland soils. Nor do they <br />object to the post mining land use standard for the Morgan Property being irrigated <br />cropland. They do object to a number of points in the plan, as set forth below. <br />