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map unit areas south of BB Road, on irrigated lands owned by the Morgan family. <br />Concerns were raised by property owners and the NRCS in late 2007 and early 2008 <br />regarding the soil handling practices being employed on these high quality agricultural <br />soils. A February 11, 2008 memorandum from NRCS soil scientist David Dearstyne <br />(permit Attachment 2.04.9-10-2) emphasized the fact that both the Barx and Darvey soil <br />types that are the primary components of the 98E map unit are prime farmland soils, <br />despite certain erroneous information from an outdated NRCS publication regarding pH <br />values, and despite the fact that the Darvey soil is not listed in the San Miguel Area S&I <br />Survey. Based on Mr. Dearstyne's letter and other sources of information (field <br />observations, as well as further correspondence/discussion with the operator, <br />landowners and NRCS staff), the Division determined that it was critical that soil <br />handling practices within the portion of the permit area south of BB Road and west of <br />2700 Road (dominated by 98E soils) revert to the two lift operation without delay. <br />These operational changes were implemented in the field in February 2008 and <br />incorporated into the approved permit within Technical Revision No. 57 (TR-57), <br />approved in March 2009. <br />Based on site,-observations, -correspondence and =discussion--with ° NRCS staff and <br />landowners, and permit information, it is clear that. srg'ficant portions of the Morgan <br />4 <br />property, which are dominated by the 98E soils aresrr?ntly irn anted or were irri acted ?. <br />in. the recent ast rior to mme disturbance: .1 -lt appears likely-that a substantial portion <br />fi <br />of the 107.96 acre Morgan property wit hin the permit area, located southwest oT-the <br />cottl?r of 2760-Road and BB Road,_would_qualify as, Prime._Farmland, based on the 4 <br />presence of prime farmland soils, and historic-and ongoingirriated..crop production. <br />Within the, ermit a ication Harr ' .e asa Wended b TR-57 an3-TR-58 WFC refers to <br />-.... <br />the entire Morgan acreage as Prime Farmland. The arjtive also commits to <br />soil salvage, replacement, and han ma ° nractices that- wiTT-c?nfnr,,, w,t P <br />r soil handling re uirements for hose < ortions ,of _ -the Morgan properly <br />stu er January 2009,,-., along. -with practices . to ensure and demons ate <br />replacement of adequate :topsoil- and "suitable overburden" subsoil on those portions of <br />the Morgan proper ty that had been,disturbed prior to. the end of January 2008. Finally, <br />amended reclamation plan narrative on page 2.05.4(2)(e) 19C includes the commitment <br />_...that "prior to submittal of Phase II or Phase Ill bond release, the permit,.will, be revised <br />to specify that areas reclaimed to ir1 -ated agricultural use west of 2700 Road and south <br />of 'BB Road will be classified as Irrigated Cropland=postmining land-e5„and as such <br />will°be subject to Irrigated.Cropland success standards". <br />As noted, amended-permit narrative refers. to the Darvey-Barx' soils on the-Morgan <br />property as Prime Farmland, and narrative- further indicates that the entire 107:96- acres <br />would-_b e treated as Rene Farmland from _an operational and -reclamation perspective. } <br />However, close readmg of the vanous referenced ZCS letters and memoranda and <br />associated documentation indicates that no formal determination has been made as to <br />whether the entire extent or only some portion of the 98E map units on the Morgan <br />i <br />property meet the Prime Farmland historic use/adequate irrigation water supply criteria. ? <br />47 <br />t-- , S? c.?e •??,.- wS -?ev?-?? S ice e (1'