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from the property to another property, and that as a result, the soils will be <br />restored to prime farmland standards, but the area will be reclaimed to dryland <br />pasture. The same area is described in numbered Paragraph (3), in sub-section <br />10.4 of Section 2.04.9, referred to as "small area in northwest portion of permit <br />area on WFC property", and in the first paragraph of sub-section 8.1.3 of Section <br />2.05.4(2)(d). <br />This area includes (in essence corresponds with) an area addressed in a letter of <br />June 27, 2008 from NRCS to DRMS (copied to WFC), which states "...the 3.52 <br />acres of Begay soil (map unit symbol 98A) on the Western Fuels-Colorado <br />property in the far northwest comer of the permit area is officially considered <br />Prime Farmland. This letter was included in PR-6 within Attachment 2.04.9-10. <br />The letter identifies the area of 98A soil in question as Prime Farmland, not <br />"potential prime farmland" or "prime farmland soils". <br />It may be the case that, due to the limited acreage of the unit, management for <br />crop production would not be economical and as such, the area would not merit <br />Prime Farmland designation. However, a letter of clarification from NRCS <br />addressing this issue and reversing the Prime Farmland determination would be <br />required before the Division would approve a plan for reclamation of the parcel to <br />dryland pasture. <br />Please address this inconsistency between the proposed plan and the NRCS <br />Prime Farmland determination, and either revise the reclamation plan to <br />conform with Prime Farmland requirements (including relevant text in <br />Sections 2.04.3, 2.04.9, 2.05.4(2)(d), 2.05.4(2)(e) and Maps 2.04.9-1, 2.05.4-4 <br />and 2.05.4-5), or provide NRCS documentation that, due to the small acreage <br />of the unit and associated economic considerations, it does not qualify as <br />Prime Farmland. Note that, if the NRCS does confirm that the small area <br />does not qualify as Prime Farmland, it would still be reclaimed as "Potential <br />Cropland" (PC), and Map 2.05.4-5 will need to be amended to reflect the PC <br />designation. <br />10. There are a couple errors in the legend of Map 2.05.4-5 that need to be corrected. <br />IC is described as "Cropland Irrigated Grass Hay", and for Potential Cropland <br />(PC), no seedmix is listed and the notation states "Not Seeded". <br />Please correct the legend to properly identify IC as "Cropland Irrigated <br />Alfalfa Hay", and to properly note that PC lands will be seeded with the <br />Dryland Pasture seed mix (Seed Mix 8). <br />It. There is an incomplete sentence fragment in the 3`d sentence of numbered <br />paragraph (1), under sub-section 10.3 of Section 2.04.9 ("Although the 70B and <br />D70B soils identified"). Please amend the wording as appropriate.