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a positive prime farmland determination was made for the Morgan Property in <br />February, 2008 Z <br />Following this determination DRMS ordered that WFC implement changes <br />to its mining and soil handling practices to account for the presence of prime <br />farmland soils. But, as of February, 2008, approximately 51.8 acres of the 108 <br />acre Morgan Property had been stripped of topsoil. Thus, although prospective <br />changes to mining practices were undertaken, unresolved was what to do about <br />those lands that had been mined and stripped of topsoil in violation of the prime <br />farmland regulations of SCMRA. <br />PR6 was submitted to DRMS in November, 2009. PR6 addressed land use <br />designations post- mining, revegetation plans, prime farmland standards, topsoil <br />replacement, and irrigation. Most of the application focused on the Morgan <br />Property, though properties owned by WFC and two other landowners were also <br />affected. <br />Z The Morgan family was excluded from these consultations between the <br />government agencies and WFC, and consequently they were unable to provide any <br />meaningful input as to operational changes that should have been implemented as a <br />result of the positive prime farmland determination. But, the Morgans agree that <br />prime farmlands are present on the Morgan Property. <br />4 <br />