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irrigated pasturelands and irrigated croplands at New Horizon, aze reference areas as <br />described in Rule 4.15.7(3), and standards based on a historic record derived from <br />statistically adequate samples collected over a period of several years [4.15.7)(2)(d)(v)]. <br />The above discussion is to provide background for the following requests. Please let us <br />know if you feel the characterization is inaccurate or incomplete. <br />a) Based on review of the permit area Soils Baseline Map, it would appeaz that the <br />shallow, less productive soil types do indeed predominate in the imgated pasture areas <br />east of 2700 Road and south of BB Road, but it also appears that the relatively deep, <br />productive, 98E, 98D, and 98G soil map units predominate within the one irrigated <br />pasture pazcel located east of 2700 Road but north of BB Road. Based on the soils <br />map, it would appear that the production standard for the irrigated pasture area to the <br />north of BB Road and East of 2700 Road should be consistent with the irrigated <br />pasture areas to the west of 2700 Road, and that a lower standard should apply only to <br />those areas south of BB Road and east of 2700 Road. Please review the map and <br />other relevant information, and amend the application as suggested or provide <br />appropriate justification for use of 2700 Road as the sole boundary between "low <br />production" and "high production" areas. <br />b) OSM rules that require inclusion of technical documents that are the basis of technical <br />standards within approved state regulatory program regulations have very recently been <br />changed. New OSM rules no longer require standards of success to be included within <br />approved state regulatory program regulations, but they do require that "standazds for <br />success... shall be selected by the regulatory authority, described in writing, and made <br />available to the public". Preamble narrative associated with the amended federal rule <br />makes it cleaz that success standard approaches, if not included within the state <br />regulations, would need to be included within an official document such as a guideline <br />or similar programmatic document that would be subject to public review and <br />comment. Amendment of DRMS rules to specifically allow for the type of technical <br />standards approach used (and proposed) at New Horizon, would first require approval <br />of a State rule change to eliminate the current requirement for OSM approval, and <br />second, would require development and approval of a State Guideline or similar <br />document that would authorize the development of standazds for agricultural lands <br />based on the professional recommendation of local NRCS officials, when applicable <br />published information is not available, and use of reference areas or historic records is <br />not practicable. This could possibly happen, but substantial time would be required, <br />and ultimate approval of the approach within a programmatic document to be applied <br />statewide cannot be guaranteed. <br />As such, we request the following. Please reevaluate the use of the reference area <br />or historic record approach for establishment of standards of success for irrigated <br />pastureland and irrigated cropland at New Horizon. Please investigate the <br />potential for lease or purchase of (ands in the permit area vicinity that would not <br />be disturbed by mining, are located on soil types representative of "high <br />productivity", and "low productivity" irrigated pastureland and irrigated hay <br />