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<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despite certain erroneous information from an outdated NRCS publication regarding pH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
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