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12. In addition to the concern noted in Item 9 above regarding the small area of 98A <br />soil, there is some confusing and we believe erroneous use of the term "prime <br />farmland soil" in certain text within Sections 2.04.3, 2.04.9, 2.05.4(2)(d), and on <br />Maps 2.04.9-1 and 2.05.4-4. <br />In numbered paragraph (3) of Section 2.04.3 sub-section 6.0, the statement in the <br />second sentence that "...the land is not considered prime farmland soil by the <br />NRCS..." should state that "...the land is not considered Prime Farmland by the <br />NRCS..." <br />There is confusion between the terms Prime Farmland and prime farmland soils <br />throughout sub-section 10.4 of Section 2.04.9. The sub-section heading reference <br />to "Prime Farmland Soils" would seem to more properly be "Prime Farmland". <br />References in numbered paragraphs (1), (4), and the second sentence of (5) to <br />"prime farmland soil" would more properly be stated as "Prime Farmland". The <br />statement at the end of sub-section 10 "...total area to be treated as prime <br />farmland is 107.96 acres (all Morgan property in the permit area)", would appear <br />to me more accurate if it were stated that "...total area to be treated as prime <br />farmland soil is 112.64 acres (all Morgan property in the permit area plus the 98A <br />soil area in the NW corner of the permit area on WFC property). The total area to <br />be reclaimed to full Prime Farmland criteria will depend on final determinations <br />regarding acreage that can be adequately irrigated with water available during the <br />liability period." <br />The "areas not considered prime farmland soil" in subsections 8.1.4 and 8.1.5 of <br />Section 2.05.4(2)(d) would more accurately be described as "prime farmland soil <br />areas that NRCS has determined do not qualify as Prime Farmland". <br />The reference to "Areas Not Considered Prime Farmland Soils" on Map 2.04.9-1, <br />with respect to 98E, 98A, and D70B soils on the Lloyd and Benson properties, <br />and in the southeast portion of the original permit area would appear to more <br />accurately be labled "Prime Farmland Soil Areas Not Considered Prime <br />Farmland". <br />Please review these discrepancies/inaccuracies, and amend as appropriate. <br />Rule 2.05.3(5) Topsoil Removal and Storage; Rule 2.05.4(2)(c) Reclamation Plan for <br />Removal, Storage and Redistribution of Topsoil and Subsoil <br />13. In subsection 10.1 of Section 2.05.4(2)(d), there is reference to an area where <br />selected overburden was approved and used for plant growth medium due to <br />lower topsoil recovery than originally projected, and Map 2.05.4-4 is referenced <br />for the location of the variance area. On the current approved version of Map <br />2.05.4-4, there is a 16.44 acre area in the location of Pond 7 and to the north of <br />Pond 7, labeled "9 Inch Suitable Subsoil or Backfill Replacement". On the PR-6 <br />6