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,i <br />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 farmlands 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despite certain erroneous information from an outdated NRCS publication regarding pH 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 Sail <br />Survey. Based on Mr. Dearstyne's letter and other sources of information (field <br />observations, as well as further correspondenceldiscussion 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 />B• aced on site Oservations, correspondence and =discussion-' with, NRCS staff and . <br />landowners, and permit information, 'it is clew that significant -ortions,of the Morgan <br />property, which are dominated by the 98E soils, ?are?su ntly irrigated or were irrigated ; <br />urn. the recent, ast x or to-'*- 'm` ne disturbance. Ita m ley that a substantial portion <br />of the 107.96 acre Morgan property w in` the permit are located southwest the <br />norntr o7U4toad an _ BB Roach,_would`qualify as, Prime. Farmlands based tin the <br />ed crop production. <br />p?reseric of prime farmland soils, andu ,cc nd on?gomg Ir. <br />W ,_id n:the,, avnl,cLtion•n?,as amended b. TR .57 an 58; V?FC.re refers, to <br />the entire Morgan acreaee as Prime Farmlan. e i native also commits to <br />soil handling t 6 rements or those rtions .,of the , Morgan prop i y <br />er ariuary 20Q8,y along:. with , practices to, ensure . an demonsate <br />replacement of adequate :topsoil and "suitRble overburden" subsoil on those pofi:is of <br />the Morgan property that. ,had bee4=disturbed prior to the end of January 2008 Finally, <br />amended. reclamation plan_narrahve on page 2.05 4(2)(0) 19C.mcludes the_comm,itment <br />,that ` ?nor to submittal of Phase II'or Phase III bond xeleas e, the perrnit,will be revised <br />;._.=. <br />to specify that areas recmmgated agriclturakuse west ,of 2700 Road and south <br />of'8B` Road will be`'classifted as Tliigafed Cropland-pdst?ng4a _v, ;?,.Zd scs ch <br />will.be,subject t67"gated.Cropland success standards". <br />As??n s amend+sd pei;mit iarra ve r?f?rs- to .the Darvey=Barx soils on the-Morgan <br />'eity as Prime F i'mland and narrative. further indicates that tfie `elifire"147° 90- acre§ <br />b?-mated a Fatml d ft ffi ah-o° eratioriai .and! -reclarnatio?r:% .erspective. <br />However, close reading of the van us referenced NR etters and memoran a 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 />property meet the Prime Farmland historic use/adequate irrigation water supply criteria. <br />Sb- ?(10l ?? X47 <br />?,}_ S a,,r, c,?e e1w's