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0 <br />• <br />?5 <br />G1981-008<D` t ?c-rl YV1 22-Jan-2010 <br />PR-06 PAR C?-'v-??C`? of 26 <br />Tv? qi?D QA-, ?Zk?? <br />provided in the application indicates that historicallY, most of the Morgan property ha,s1 <br />been irrigated and used for crop production. _ <br />Based on soil survey documentation and NRCS review, WFC has acknowledged that the <br />entire acreage is considered prime farmland soil or potential prime farmland, and has <br />committed to implement specific soil salvage, handling, and replacement procedures <br />applicable to prime farmland soils over the entire property. At issue is the extent of <br />acreage on the property that can be adequately irrigated with the irrigation water <br />available to WFC, to establish and maintain alfalfa hay cropland stands at appropriate <br />production levels. In a letter dated August 4, 2009, the NRCS Norwood area Resource <br />Conservationist stated that "if, during reclamation. there are portions of these Drime <br />.farmland soils where adeauate ini?vsatenis not availahiP to urnu? a rrnn-then <br />technically they lose their prime farmland status. Jesus situation, it is unrealistic R <br />these argas to be held to a cropland production goal. Alternatively, the reclaimed <br />vegetative community could be a mixture of drought to eran? t grasses ana zoiv ,and <br />available for these ands tl would again be considered prime farmland, pa- cularl <br />since the soils h een reclaimed accordingly. ! 1 <br />WFC states that the irrigation water available to them for irrigation use on the Morgan <br />property during the reclamation liability period is 50 shares of CC ditch water, and they <br />have provided a copy of the lease document that specifies 50 shares. Within Section <br />2.05.4(2)(e)(2.0) of the application, WFC presents reasoning to support a conclusion that <br />1.2 acres per share of water could prudently be irrigated using a side roll sprinkler, and <br />based on that ratio, they have proposed a reclamation plan for the Morgan property that <br />would entail establishment of irrigated alfalfa hay cropland (Prime Farmland) on 60.1 <br />acres of the Morgan property, with the remaining 47.9 acres to be reclaimed to "Potential <br />Cropland" (i.e. soil criteria meeting prime farmland requirements, seeded to meet dryland <br />pasture revegetation standards). WFC presents supporting calculations for their projected <br />acre/share ratio in Attachment 2.05.4(2)(e)-7 of the application. <br />The Division accepts the concept put forth by WFC of reclaiming a portion of the acreage <br />to irrigated cropland and a portion to potential cropland, based on the extent of acreage <br />that will be irrigated. This is consistent with the evaluation presented in the August 4, <br />2009 NRCS letter. However, in a letter dated December 8, 2009, NRCS identified a <br />number of flaws in the supporting information presented in Attachment 2.05.4(2)(e)(7), <br />regarding calculation procedures and data reliability., In the. letter, NRCS presented <br />justification to validate their earlier determinations regarding crop water use and side roll <br />sprinkler capabilities. NRCS concluded that, with good farming practices and proper <br />irrigation water management, 50 shares of CC Ditch water should be sufficient to supply <br />three full length sideroll sprinklers, servicing 71 acres, and grow a productive alfalfa crop <br />that meets the average yields established for bond release. <br />Please revise Attachment 2.05.4(2)(e)(7) to reflect the changes specified by MRCS in <br />their December 8, 2009 letter, and revise the reclamation plan narrative, tables, and <br />Map 2.05.4-5 to conform with sideroll irrigation and alfalfa hay crop production on <br />' 1? ?a-(:), ??'