2010-01-22_REVISION - C1981008 (2)

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C-1981-008 PR-06 PAR 22-Jan-2010 Page 21 of 26 provided in the application indicates that historically, most of the Morgan property has been irrigated and used for crop production. Based on soil survey documentation and NRCS review, WFC has acknowledged that the entire acreage is considered prime farmland soil or potential prime farmland, and has committed to implement specific soil salvage, handling, and replacement procedures applicable to prime farmland soils over the entire property. At issue is the extent of acreage on the property that can be adequately irrigated with the irrigation water available to WFC, to establish and maintain alfalfa hay cropland stands at appropriate production levels. In a letter dated August 4, 2009, the NRCS Norwood area Resource Conservationist stated that "if, during reclamation, there are portions of these prime farmland soils where adequate irrigation water is not available to grow a crop, then technically they lose their prime farmland status. In this situation, it is unrealistic for these areas to be held to a cropland production goal. Alternatively, the reclaimed vegetative community could be a mixture of drought tolerant grasses and forbs, and designated as dryland pasture. If, at a later date, adequate irrigation water becomes available for these lands they would again be considered prime farmland, particularly since the soils have been reclaimed accordingly." WFC states that the irrigation water available to them for irrigation use on the Morgan property during the reclamation liability period is 50 shares of CC ditch water, and they have provided a copy of the lease document that specifies 50 shares. Within Section 2.05.4(2)(e)(2.0) of the application, WFC presents reasoning to support a conclusion that 1.2 acres per share of water could prudently be irrigated using a side roll sprinkler, and based on that ratio, they have proposed a reclamation plan for the Morgan property that would entail establishment of irrigated alfalfa hay cropland (Prime Farmland) on 60.1 acres of the Morgan property, with the remaining 47.9 acres to be reclaimed to "Potential Cropland" (i.e. soil criteria meeting prime farmland requirements, seeded to meet dryland pasture revegetation standards). WFC presents supporting calculations for their projected acre/share ratio in Attachment 2.05.4(2)(e)-7 of the application. The Division accepts the concept put forth by WFC of reclaiming a portion of the acreage to irrigated cropland and a portion to potential cropland, based on the extent of acreage that will be irrigated. This is consistent with the evaluation presented in the August 4, 2009 NRCS letter. However, in a letter dated December 8, 2009, NRCS identified a number of flaws in the supporting information presented in Attachment 2.05.4(2)(e)(7), regarding calculation procedures and data reliability. In the letter, MRCS presented justification to validate their earlier determinations regarding crop water use and side roll sprinkler capabilities. NRCS concluded that, with good farming practices and proper irrigation water management, 50 shares of CC Ditch water should be sufficient to supply three full length sideroll sprinklers, servicing 71 acres, and grow a productive alfalfa crop that meets the average yields established for bond release. Please revise Attachment 2.05.4(2)(e)(7) to reflect the changes specified by NRCS in their December 8, 2009 letter, and revise the reclamation plan narrative, tables, and Map 2.05.4-5 to conform with sideroll irrigation and alfalfa hay crop production on