2010-01-22_REVISION - C1981008 ‎(2)‎

• Permit No: C1981008
• IBM Index Class Name: REVISION
• Doc Date: 1/22/2010
• Doc Name: Preliminary Adequacy Review Letter
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: PR6
• Email Name: MLT
• Media Type: D
• Archive: No

C-1981-008
PR-06 PAR
22-Jan-2010
Page 3 of 26
irrigated cropland (25.02 acres)... mapped in 1987 as Cropland (IC) immediately north
and west of Pond 7" have been determined to be irrigated pasture (IP) areas instead". On
revised Map 2.04.3 in PR-6, these two areas are mapped as Pastureland-Irrigated Hay
(IPH). The justification given for re-classification of the pre-mining land use for the
25.02 acre area northwest of Pond 7 from Cropland (IC) to irrigated pasture (actually to
IPH), is provided in sub-section 3.0. Essentially, it appears the areas had large areas of
shallow soils or boggy ground, and were dominated by Unit 30C soils that "are generally
shallow, have a poor capability class, and require a high level of management inputs".
The two fields had not been tilled after harvest the previous year and were characterized
by volunteer barley and a host of annual and perennial weedy species. From the
description, it appears these fields were annual grain croplands that were not intensively
managed, and had low production potential. The Division recommends that WFC add a
pre-mine land use category to accurately describe the 25.02 acres in question as
Cropland-small-grain.
Please amend the referenced text sections and Maps 2.04.3 and 2.04.10 for clarity,
and to be internally consistent.
4. 50.85 acres of land within the eastern and central portions of the Morgan property in the
permit area is mapped as IC (Cropland Irrigated Alfalfa Hay) on Maps 2.04.3 and 2.04. 10
of PR-6. The distinction between areas mapped as IC and areas mapped as IP is
supported by the 1998 color aerial photo, which shows dark green areas of apparent high
productivity corresponding with the IC map area designations. Review of additional
aerial photos from 1973 (b&w), 1993 (b&w), and 2005 (color), provided in the PR-6
submittal would seem to indicate that irrigated areas of apparent high production have
occurred across the extent of the Morgan property within the permit area over the years,
but areas of relatively higher and lower production are different in the different years.
Presumably, changes in the location of the high production areas reflect management
during a particular year. This apparent use pattern, combined with the dominant presence
of prime farmland soils across the property, and statements made to the Division in recent
years by the Morgan family, regarding historic cropland use, would seem to justify IC
designation for lands in the western portion of the property that are currently designated
IP (37.61 acres).
Please address this observation, and provide justification for the Morgan property
land use designations on Maps 2.04.3 and 2.04.10, or revise the maps to re-designate
the IP acreage in the western portion of the property to IC.
Rule 2.04.9 Soils Resource Information
There were no substantive changes proposed within the PR-6 application pertinent to the
requirements of Rule 2.04.9.