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TDN Response <br />New Horizon Mine <br />April 23, 2010 <br />Page 3 <br />Intermountain Resource Inventories, Inc., a consultant to WFC. On the Morgan Property 87.07 acres <br />were mapped as Soil Map Unit 98E which is the Darvey -Bari complex. Depths of topsoil in the <br />Darvey -Barx unit on the Morgan property ranged from 39 to 69 inches. These soils were used <br />primarily for irrigated hayland or pastureland. <br />An investigation of prime farmlands was conducted during the 1998 baseline soils inventory. Of <br />particular interest was Map Unit 98E, the Darvey -Bari complex. Key language from that report <br />states: <br />Barx, irrigated is a prime farmland soil in Colorado (Colorado Important Farmland <br />Inventory, NRCS Colorado). This soils falls within the criteria listed in the National Soil <br />Survey Handbook (1996 edition) for prime farmland soil. However, the Colorado <br />Important Farmland Inventory states on page 3, "irrigated soils that have a pH higher <br />than 7.4 are considered as having high conductivity and therefore are not considered <br />prime." Barx soil as used in this survey is not considered as being prime farmland <br />because the pH is higher than 7.4 in all horizons. <br />The soils in the relevant area had a pH higher than 7.4 and the relevant lands were not designated as <br />prime farm land on the NRCS Colorado Important Farmland Inventory. At the time of review the <br />Colorado Important Farmland Inventory was a current document. Accordingly, the Division made a <br />negative prime farmlands determination based on the soils survey and the reference to the NRCS <br />publication, Colorado Important Farmland Inventory. This finding was consistent with previous <br />negative findings for the Barx soil map unit at the New Horizon Mine as documented in an October 14, <br />1992 NRCS letter and a March 29, 1996 NRCS letter. <br />A re- evaluation of the negative prime farmland determination was initiated when the Division was <br />notified that prime farmlands may exist. The Division requested review by the NRCS of the prime <br />farmlands determination for the Morgan property on January 14, 2008. In response, the Division <br />received correspondence dated February 11, 2008 from David Dearstyne, Soil Scientist with NRCS. <br />The letter addresses the issue of prime farmlands. First, Mr. Dearstyne explained that the Colorado <br />Important Farmland Inventory document, used in the PR -5 baseline evaluation, incorrectly stated that <br />prime farmland designation in Colorado would not be given to any soil with a pH of over 7.4. Mr. <br />Dearstyne explained the Important Farmland Inventory document was in error and that the threshold <br />pH should have been 8.4, not 7.4. Second, he states that the document (Colorado Important Farmland <br />Inventory) developed around 1980 was no longer current. <br />As soon as it was discovered that certain soil types within the New Horizon permit area were <br />potentially prime farmlands, a meeting was convened between representatives of the Division, WFC, <br />and the NRCS. The purpose of this meeting (held on February 15, 2008) was to establish the extent of <br />prime farmlands and to make immediate adjustments to soil handling procedures that would be <br />consistent with regulations governing mining on prime farmlands. (At the time of the meeting, mining <br />operations had already progressed partway through the prime farmlands on the Morgan property.) In <br />addition to modifying the topsoil salvage and handling plan for current and future disturbance, a <br />sampling protocol and criteria were established for evaluating the quality of prime farmland areas on <br />the Morgan property that had been already mined and backfilled. As a result of the February 15, 2009 <br />meeting, the Division directed WFC to make immediate changes to the topsoil salvage and stockpiling <br />