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o )? <br />U . <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 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despite certain erroneous information from an outdated NRCS publication regarding pH 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 Soil <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;_.gbservations,...vorrespondence -and.-disemsiotro- with . i. RCS :.. staff and <br />la liwn&is, an d permit information, it-is clefit"that sigt fcant,porhons.-of the Morgan <br />property, which are dominated by the 98E soils, are currentlydrrigated or,were. mgated <br />in the recent past prior ,to mine iskurbance: -It appears likely that a substantial portion <br />of the 107.96 acre Morgv4ropp y vtr'if tie 'Vermit--area, located southwest of the <br />• corner-of 27- Road -and BB Road, ,w.ould qualify. ..as Prime Farmland, based on the <br />presence of prime farrnlansi ,soils,.and_historic-and-onwgoing irngated,crop production. <br />Withu, the permit. application.narrative: as=amended b3 TR-57 •and T- R 5,85 WF+G:.ref4s, to <br />the entire Morgan , acreage as Prime Farmland. The permit narrative also commits to <br />soil salvage, replacement, and handling practices that.. «111 'conform with PtSie <br />Farmland soil handling requirement for those portions of the Morgan propefty <br />}r - <br />disturbed after Ianuary` 208, along with ., practices to ensure and demonstrate <br />replacement of adequate topsoil and: "suitable;=overburden" subsoil on those porrior s of <br />the n!Irgan property that had b en :disturbed prior to the egci of 7anuary 2Q08 k$ Finally, 11 amended reclamation plan narrative on page 2.05.41(2)(e)-19C includes the commitment <br />pernut-,wil11_ be revised <br />-that 4` `-6r to submittal of Phase Ih or Phase Ill bond ,release, the< <br />to snec? t. at areas rec dime -to irrigated aQncu aura use:west::of 2700 Road and south <br />wject to hgated Cropland success standar s . <br />However, close reading of the vanous reference 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 />property meet the Prime Farmland historic use/adequate irrigation water supply criteria. <br />b4je1 +o <br />W weer --Q Q MOY-rrVS C51_ *_Q . 1°sZ <br />?- cA e.-f-S ` X47