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17. The text notes that direct haul replacement of live topsoil would be preferable for <br />cropland areas, but due to mine plan circumstances, substantial areas of cropland <br />and potential cropland will be reclaimed with stockpiled topsoil. NRCS has <br />indicated that they have observed significant production benefits on depleted <br />croplands from incorporation of manure. It may be the case that stockpiled <br />cropland soils would benefit from manure incorporation. <br />Please consider including manure incorporation at NRCS recommended <br />rates as an additional practice associated with cropland soil replacement. <br />Use of the practice on a relatively small area initially on a trial basis, would <br />be acceptable. <br />Rule 2.06.6 Prime Farmlands <br />18. Rule 2.06.6(4) requires that, in order for the Division to approve a permit for the <br />reclamation of prime farmland, a written finding must be made that the approved <br />postmining land use will be cropland. A question that has not been resolved to <br />the Division's satisfaction in the PR-6 application, is the extent of Prime <br />Farmland on the 107.96 acre Morgan property in the permit area, located <br />southwest of the comer of 2700 Road and BB Road. The area is dominated by <br />Darvey-Bari soils, which qualify as Prime Farmland when irrigated with an <br />adequate and dependable supply of water. Evidence provided in the application <br />indicates that historically, most of the Morgan property has been irrigated and <br />used for crop production. <br />Based on soil survey documentation and NRCS review, WFC has acknowledged <br />that the entire acreage is considered prime farmland soil or potential prime <br />farmland, and has committed to implement specific soil salvage, handling, and <br />replacement procedures applicable to prime farmland soils over the entire <br />property. At issue is the extent of acreage on the property that can be adequately <br />irrigated with the irrigation water available to WFC, to establish and maintain <br />alfalfa hay cropland stands at appropriate production levels. In a letter dated <br />August 4, 2009, the NRCS Norwood area Resource Conservationist stated that <br />"if, during reclamation, there are portions of these prime farmland soils where <br />adequate irrigation water is not available to grow a crop, then technically they <br />lose their prime farmland status. In this situation, it is unrealistic for these areas <br />to be held to a cropland production goal. Alternatively, the reclaimed vegetative <br />community could be a mixture of drought tolerant grasses and forbs, and <br />designated as dryland pasture. If, at a later date, adequate irrigation water <br />becomes available for these lands they would again be considered prime <br />farmland, particularly since the soils have been reclaimed accordingly." <br />WFC states that the irrigation water available to them for irrigation use on the <br />Morgan property during the reclamation liability period is 50 shares of CC ditch <br />water, and they have provided a copy of the lease document that specifies 50 <br />8