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0 <br />• <br />�s <br />`� b ✓ 1 C `� 22- Jan -2010 <br />C- 1981 -008� - 1 - - \ <br />PR -06 PAR � <br />G + \ wr �. C of 26 <br />provided in the application indicates that historically, most of the Morgan property h <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, +here are portions of these grim <br />f armland soils where ade en <br />fo r <br />t�.rhnicallv they lose their crime farmland status. In h s situation, it is unr ealisti c. <br />_ thesear as to be held to a cropland production goal. Alternatively, the reclaimed d <br />ye etative community could e a mixture of drought tolerant grasses an , <br />desi at at a ater date ade uate irrigation water a es <br />available for these 1 thq—would again be considered prime farmland, particularl <br />since th soils have been reclai accordingly <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 S, 2009 letter, and revise the reclamation plan narrative, tables, and <br />Map 2.05.4 -5 to conform with sideroll irrigati and alfalfa hay crop production on oc\ mc)(Z-�ky) <br />