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10) It is important to point out that the 1998 pre-mine survey of vegetation and land <br />use showed no cropland on the west side of 2700 Road. This is shown on Map <br />2.04.10. We have designated 22.89 acres as cropland in the post-mine land use as <br />shown on Map 2.05.4-5 on the Morgan property. The pre-mine survey classifies the <br />majority of this area as Irrigated Pasture, which contained significant levels of <br />grasses. This is in contradiction to what the Morgan's say in the protest letter about <br />alfalfa being the only plant that is used on their land in this area. The 1998 photo <br />shows IPH being flood irrigated and has raged edges. A 2000 photo shows the same <br />field abandoned. <br />11) An allegation was made in the Morgan protest letter that WFC did not use <br />irrigation water for irrigation for three weeks after it was available because they were <br />using it for dus# control. WFC only uses 2% of the irrigation water that they own for <br />dust control. MSHA mandates dust suppression from a health and safety standpoint. <br />Also, WFC has no control over the time that water enters their property once the <br />ditch is turned on. It has been seen that upstream users of the ditch delay when <br />water is available at the mine, but this is out of the control of WFC. <br />12) The land use designations which removed irrigated hayland from the pre-mine <br />and post-mine list were based on desires expressed by the Division in the November <br />2006 memo. <br />13) WFC commits to planting whatever species of alfalfa is best suited for the <br />reGaimed areas. We can work with the landowners and NRCS on this choice. <br />14) Regarding the suitability of the reference area, it is important to point out to some <br />landowners that there is no direct comparison to the reference area. There are <br />adjustment factors which take into account some of the better soils which exist in the <br />western portion of the permit. in some cases, this increases the required level of <br />production by 20°!0 over the reference area. <br />15) The standards for Irrigated Cropland have not been changed in years. The <br />standards which were set for this land use were based on letters from the landowners <br />reporting their 1~ cut production. It should be noted that the approved 1.84 tons for <br />first cutting of alfalfa is based upon a field wt (with moisture). That is how it was <br />measured by the landowners, whose averages were used to arrive at the 1.84 tons <br />per acre standard. A methodology of measuring actual production needs to be <br />agreed to, such as weighing 30 random bales (55-85 pound per bale) and doing a <br />mathematical average to determine an aaverage wt per bale°, then multiplying all <br />bales by the average. <br />16) If it is determined by Jim Boyd that it is not good practice to put 15-20 Ibs of <br />alfalfa and 70 Ibs of oats per acre during initial seeding, the permit will be revised to <br />reflect this. Whatever is determined to be good practice for the initial seeding of <br />Page 9 of 10 <br />