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4 ,2Q, 1 <br />r" <br />. map unit areas south of BB Road, on irrigated <br />NRCS ina <br />own <br />lte 2007 and early 2008 <br />Concerns were raised by property owners and he <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 o sued S the S Mi publication g Are g pH <br />soil <br />values, and despite the fact that the Darvey not <br />Survey. Based on Mr. Dearstyne's letter and sources owith inform he ope (ator <br />observations, as well as further corresp ondence/discussion <br />landowners and NRCS staff), the Division determined that it was critical that soil <br />handling practices within the portion of the pe the two lift op ra R <br />io without delay. <br />2700 Road (dominated by 98E soils) revert to a 2008 and <br />These operational changes were implemented in the field in February <br />incorporated into the approved permit within Technical Revision No. 57 (TR -57), <br />approved in March 2009. <br />------`� ~ ondence and discussion with NRCS­ staff and <br />Based on site . observations, corresp <br />landowners, and permit iriforination, it is cleat "that sigmficant,.porhons.. of the organ <br />property, which are dominated by the 98E soils, are currently irrigated or were,irrigated <br />in the recent past prior to riiine chsturbance It appears likely that a substantial portion <br />a r t within the permit -area, located southwest of the <br />of the 107 96 acre Morgan:p y <br />corner 27 8E} :Road and "BB' Road; °would qualify. as Prime Farmland, based on the <br />. irrigated, production. <br />crop, <br />resence of prime farmland. soils, and historic and ongoing s to <br />Within the permit applicatiownarrative as de The permit narrative also Comm is to <br />the entire Morgan „acreage as Prime Farmland _p <br />r .._...::.. <br />soil salvage, replacement, and handli ng practices that conform with PriYne <br />p g, P p y <br />Farmland soil handling t or o <br />requiremens `f thse , ortions of the Moran ro ert <br />1 <br />disturbed after January 2008, . ;along ; with practices to ensure and demonstrate <br />replacement of adequate topso� and "suitle :overburden subsoil on those fly, <br />the Morgan property that had been< disturbed prior to.. the, end of January <br />�.) (,) .. _ .-., <br />amended reclamation, plan narrative on page 2 05 4 2 e 19C includes the comm itment <br />xhat " nor to submittal of Phase II or Phase III bond, re ease, <br />the,pernut will be revised <br />, +o,a =iI f,�ra use west of 2700 Road and sout <br />ill,Y eteta lrria ed Crouland success standard <br />nM <br />indicates <br />tr-eaieo � <br />However, close reading of the various rder N letters and memoran a an <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 />111 0Y-r } <br />