2010-05-11_GENERAL DOCUMENTS - C1981008

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P . 1 1 c ?O Page 3 F TDN :Response New-riorizon Mine April 23, 2010 llitermountain Resource inventories, trio:, a consultant to VJFG: On the Morgan the of t p o7rn ed as Soil Map Unit 98E which is the Darvey-Barn Wm? Y. Depths were in app the . Darvey-Bari unit on the Morgan property ranged. from 39 to :69 inches. These :soils .were used primarily far irrigated hayland.or'pastureland. An investigation of prime farmlands was .:conducted during the.1998 baseline soil somentoryrepO particular interest was Map Unit 98E, the Darve?°-Bat?ac complex. Key Ian?g states: -- /?, ?" farmland soil in Colorado (Colorado-important Farmland ? ?. ed is a prime try, N p Fnventory,RCS Colorado). This soils,falls within the criteria listed in the National. Soil Survey Handbook (1996 edition) for prime farmland sail. However, the Colorado . P ?? artant Farmland Inventory states on -page 3, "irrigated soils tliat have a pH high r conductivity and therefore are not cols t than-7.4 are considered as having high prime." Barx soil , as used in this survey is not considered as being prime farmland C . J\J t~>?? . 1110 ?- Y_ because t e His higher than 7: in all horizons. _ :9- e soils in the relevant area had a pH. higher than 7.4 and e relevant t .. s were not designated as prairie. farm land on the NRCS Colorado Important Farmland Inventory. At the time of review n ode a Colorado Fm ortarat Farnrtiand inventory was a current document: e Racording eference to the N RCS negative `prime farmlands determination based s qt publication, Colorado Important. Farmland Inventory. This findin- . was consistent, with previous negative findings for the Barx soil map unit at. the New Horizon-Mine a 6 ented in an October 14, 1992 MRCS letter and a March 29,:1.996 NRC.S letter. `t A re-evaluation of the negative prime farmland determination was initiated when the ivision was notified that prime. farmland, inay exist. The Division requested. review by the NRCS of d-ie prime In response, the Division farmlands determination for the Morgan property on January l4, 2008. Scientist with NR Division received correspondence dated February 11, 2008 from David Dearstyno, SIn Scientist the w Colorado ??. The letter addresses the issue of.prame farmlands- First, Mr..Dearstyne; explained Important Farmland Inventory document, used in..the PR-5-baseline evaluation, incorrectly stated. that prime farmland desrgmation'in Colorado would not be given to any soil with a. pH of over ?:4: Mr• ?_? . ? ? Dearstyr*' xplained the Important Farmland Inventory document was in error and that the threshold PH should have been 8.4, not 74. Second.. he states that the document-(Colorado Important Farmland 00 Inventory) developed around 1.980 was no longer current. LYE As soon. as :it was discovered that certain soil types within : the. New HoLizon permit..area were , potentially prime farmlands, a meeting was convened between representatives of the Division, W.FC huh and. the MRCS. The purpose .of this meeting (held on February 15, 2008) was to establish the. extern of prime farmlands and to make immediate adjustments to soil handling procedures. that would be consistent with regulations. governing mining.an prime farmlands. (At the time of the. meeting, m?ning operations-had already progressed.partway through the prime farmlands can the Morgan property.) In J? addition to irtodifying the topsoil salvage and handling plan for current and future disturbance, a sampling pirotocol and criteria were established for evaluating the quality of prime farmland:areas on n , ,? the Morgan property that :had been already mined and backfilled.. As a result of the February' 15. 2009 V meeting,`the:Divisiari directed VVFC to make immediate changes to the topsoil salvage and` stockpiling t ?-?,,