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Board mandated changes in post -mine topography which preclude furrow <br />irrigation, it was arbitrary and capricious for it to order an irrigation method that <br />will not work for established crop uses, and which will not work at all at the end of <br />reclamation. This aspect of PR6 clearly violates Rule 4.16.1. <br />III. CONCLUSION <br />Admittedly, this matter involves some technical complexity. The Record <br />reflects that DRMS put some effort into addressing the issues raised by Plaintiffs <br />and other agencies. However, the final product falls significantly short of the <br />mark, and that requires reversal here. <br />Plaintiffs respectfully request the following relief: <br />a. an order affirming the determination that the entirety of the Morgan Property <br />constitutes prime farmland and will be reclaimed as irrigated cropland. <br />b. orders determining that the Board acted arbitrarily and capriciously, and <br />setting aside the approval of PR6 due to the fact that WFC was not then in <br />compliance with SCMRA and its regulations; <br />C. Orders determining that the removal of topsoil, comingling of topsoil layers, <br />and the use of Bench One topsoil substitute violated SCMRA and its regulations, <br />30 <br />