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C-1981-008 <br />PR-06 <br />June 21, 2010 <br />Page 3 of 30 <br />4. WFC did not re-designate the western field of the Morgan Property as Irrigated Cropland. In <br />response to this question WFC added the language provided on page 2.04.3-9. This added <br />narrative is derogatory and unacceptable. Please delete that language. The Division does agree <br />with the designations proposed in PR-6, however, the terminology used remains a point of <br />objection for the Morgan Property landowner representative. Please coordinate directly with the <br />landowner representative to resolve this concern, and revise the permit document to include <br />language that clarifies and resolves the ongoing objection. It is important to recognize that <br />whether the pre-mine land use is irrigated pasture or irrigated cropland, WFC has committed to <br />reclaim all of the Morgan property to Irrigated cropland. <br />4A. WFC includes a section on the determination of prime farmlands in the Pre-mining land use <br />Section 2.04.3 Subsection 6.0. The subsection is titled "Prime Farmlands and Prime Farmland <br />Soils within the Pre-Mine New Horizon Permit Area". Prime farmland is not a land use in itself; <br />it is a designation based on soils and land historically used for crop production. WFC has <br />addressed the prime farmland designation in the soils and revegetation sections. Please delete <br />Section 2.04.3 Sub-section 6.0 that was added to the Pre-mining land use section in PR-6. <br />Rule 2.04.9 Soils Resource Information <br />4B. Please carefully review this section. Remove any outdated or incorrect information. If the <br />narrative and information is retained for historic purposes, then the permit must clearly reflect an <br />explanation that previous information was erroneous and no longer valid. <br />4C. Several NRCS letters relating to prime farmland are referenced in this section. Please make sure <br />that all of the prime farmland determination letters referenced in the section are included in <br />Attachment 2.04.9-6. Specify the location that each letter applies to. This would probably be the <br />logical attachment in which to include all letters from NRCS relating to Prime Farmland <br />Determinations as discussed in question 14 also. <br />4D. In the final paragraph of Section 10.1 reference is made to the 1992 letter from Dean Stindt of <br />NRCS regarding a negative prime farmland determination. The letter is included in Attachment <br />2.04.9-6. There is some uncertainty regarding the specific location to which the negative <br />determination applied. Please provide the map referenced in Mr. Stindt's letter, and other <br />documentation as necessary to clearly identify the location and extent of the area to which the <br />subject negative determination applied. <br />4F. Please revise the first sentence of the Item 2 Prime Farmlands definition in Section 10.3, as <br />follows: Prime Farmlands means land which has been determined by the Division in <br />consultation with NRCS to meet the definition of Rule 1.04(95). <br />4G. Please revise the Item 3 Irrigated Cropland definition in Section 10.3 as follows: This is a pre- <br />mine and post-mine land use category (IC) which applies to irrigated lands that meet the DRMS <br />Cropland definition, of Rule 1.04(71)(a). All prime farmlands in the permit area will be <br />reclaimed to irrigated cropland use.