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map unit areas south of BB Road, on irrigated lands owned by the Morgan family. <br />Concerns were raised by property owners and the NRCS in late 2007 and early 2008 <br />regarding the soil handling practices being employed on these high quality agricultural <br />soils. A February 11, 2008 memorandum from NRCS soil scientist David Dearstyne <br />(permit Attachment 2.04.9-10-2) emphasized the fact that both the Barx and Darvey soil <br />types that are the ,primary components of the 98E map unit are prime farmland soils, <br />despite certain erroneous information from an outdated NRCS publication regarding pH <br />values, and despite the fact that the Darvey soil is not listed in the San Miguel Area Soil <br />Survey. Based on Mr. Dearstyne's letter and other sources of information (field <br />observations, as well as further correspondence/discussion with the operator, <br />landowners and NRCS staff), the Division determined that it was critical that soil <br />handling practices' within the portion of the permit area south of BB Road and west of <br />2700 Road (dominated by 98E soils) revert to the two lift operation without delay. <br />These operational changes were implemented in the field in Febn-1ary 2008 and <br />incorporated into'the approved permit within Technical Revision No. 57 (TR-57), <br />approved in March 2009. <br />Based on site observations, correspondence and discussion with NRCS staff and <br />landowners, and permit information, it is clear that significant portions of the Morgan <br />property, which are dominated by the 98E soils, are currently irrigated or were irrigated <br />in the recent past prior to mine disturbance. It appears likely that a substantial portion <br />of the 107.96 acre Morgan property within the permit area, located southwest of the <br />corner of 2700 Road and BB Road, would qualify as Prime Farmland, based on the <br />presence of prime farmland soils, and historic and on-going irrigated crop production. <br />Within the permit' application narrative as amended by TR-57 and TR-58, WFC refers to <br />the entire Morgan acreage as Prime Farmland. The permit narrative also commits to <br />soil salvage, replacement, and handling practices that will conform with Prime <br />Farmland soil handling requirements for those portions of the Morgan property <br />disturbed after January 2008, along with practices to ensure and demonstrate <br />replacement of adequate topsoil and "suitable overburden" subsoil on those portions of <br />the Morgan property that had been disturbed prior to the end of January 2008. Finally, <br />amended reclamation plan narrative on page 2.05.4(2)(e)-19C includes the commitment <br />that "prior to submittal of Phase II or Phase III bond release, the permit will be revised <br />to specify that areas reclaimed to irrigated agricultural use west of 2700 Road and south <br />of BB Road will be classified as Irrigated Cropland postmining land use, and as such <br />will be subject to Irrigated Cropland success standards". <br />As noted, amended permit narrative refers to the Darvey-Bari soils on the Morgan <br />property as Prime; Farmland, and narrative further indicates that the entire 107.96 acres <br />would be treated as Prime Farmland from an operational and reclamation perspective. <br />However, close reading of the various referenced NRCS letters and memoranda and <br />associated documentation indicates that no formal determination has been made as to <br />whether the entire extent or only some portion of the 98E map units on the Morgan <br />property meet the Prime Farmland historic use/adequate irrigation water supply criteria. <br />47