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shares. Within Section 2.05.4(2)(e)(2.0) of the application, WFC presents <br />reasoning to support a conclusion that 1.2 acres per share of water could prudently <br />be irrigated using a side roll sprinkler, and based on that ratio, they have proposed <br />a reclamation plan for the Morgan property that would entail establishment of <br />irrigated alfalfa hay cropland (Prime Farmland) on 60.1 acres of the Morgan <br />property, with the remaining 47.9 acres to be reclaimed to "Potential Cropland" <br />(i.e. soil criteria meeting prime farmland requirements, seeded to meet dryland <br />pasture revegetation standards). WFC presents supporting calculations for their <br />projected acrelshare ratio in Attachment 2.05.4(2)(e)-7 of the application. <br />The Division accepts the concept put forth by WFC of reclaiming a portion of the <br />acreage to irrigated cropland and a portion to potential cropland, based on the <br />extent of acreage that can prudently be irrigated. This is consistent with the <br />evaluation presented in the August 4, 2009 NRCS letter. However, in a letter <br />dated December 8, 2009, NRCS identified a number of flaws in the supporting <br />information presented in Attachment 2.05.4(2)(e)(7), regarding calculation <br />procedures and data reliability. In the letter, NRCS presented justification to <br />validate their earlier determinations regarding crop water use and side roll <br />sprinkler capabilities. NRCS concluded that, with good farming practices and <br />proper irrigation water management, 50 shares of CC Ditch water should be <br />sufficient to supply three full length sideroll sprinklers, servicing 71 acres, and <br />grow a productive alfalfa crop that meets the average yields established for bond <br />release. <br />Please revise Attachment 2.05.4(2)(e)(7) to reflect the changes specified by <br />NRCS in their August 4, 2009 letter, and revise reclamation plan narrative, <br />tables, and Map 2.05.4-5 to conform with sideroll irrigation and alfalfa hay <br />crop production on 71 acres of the Morgan property during the liability <br />period, with the remainder of the Morgan property to be reclaimed to <br />Potential Cropland. <br />19. The PR-6 application proposes amended success standards and methods for <br />demonstration of success on Prime Farmland irrigated alfalfa cropland in <br />subsection 6.1 of Section 2.05.4(2)(e). A reference field based standard is <br />proposed to replace the currently approved technical standard. The current <br />standard is based on estimated I" cutting hay crop yields provided by three of the <br />larger farmers in the mine area, and has been reviewed and deemed acceptable by <br />NRCS. The proposed standard is referred to as a reference area in the narrative, <br />but would actually be a designated field located on the same soil type, planted to <br />the same crop and subject to the same management as the reclaimed cropland, <br />where I' cutting hay production data would be collected for a minimum three <br />year period to establish a production success standard (the average reference field <br />production for the minimum 3 year period). The proposed standard would still be <br />considered a technical standard rather than a reference area, since the three years <br />of data collection from the reference field would not necessarily coincide with the <br />three years of data collection from the reclaimed cropland. The proposed <br />9