2010-06-21_REVISION - C1981008 (2)

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C-1981-008 PR-06 June 21, 2010 Page 4 of 30 4H. The area referred to in Item 1 of Section 10.4 may not be the area to which Dean Stindt's 1992 letter applied. There may be two areas in the original permit area that received consideration as prime farmland (one larger area which was designated prime at one time, then reversed, and another location that was evaluated by Dean Stindt and determined not to be prime in 1992). See comment 4B, and revise the narrative in Item 1 of Section 10.4 for clarification. 41. The amended language in the final sentence of Item 2, Section 10.4 is not clearly worded. The sentence is no longer necessary and should be deleted. 4J. Section 16 "Topsoil Stripping Procedures after February 2008" contains narrative that is not consistent with field conditions. On the prime Morgan prime farmland, WFC has salvaged the entire thickness of Lift A (dark brown surface horizons), rather than salvaging to color change "or 24 inches, whichever is less". During recent inspection with Jim Boyd of NRCS, it was agreed that salvage of the dark brown surface horizons as Lift A, to the color change was appropriate. Please revise the section to reflect salvage of the entire thickness of the dark brown surface horizons to the color change as Lift A. Also, the subsoil (Lift B) color is described as light tan. The subsoil on the Morgan prime farmland is typically a light pink, as distinguished from the upper Bench 1 overburden, which is typically a light tan. The color change from pink to tan is the feature used by equipment operators in the field to distinguish Lift B subsoil from Bench 1 overburden. Please revise narrative in Section 16.1 as appropriate. Topsoil stripping is also addressed in the topsoil salvage section of 2.05.4(2)(d). This dual discussion creates confusion and can lead to conflicting information. Please consolidate all topsoil salvaging discussions into one section. Rule 2.04.10 Vegetation Information 5. Narrative following the reference to the designation of lands north and west of Pond 7 as Irrigated Cropland-Small Grains (ICSG) does not seem consistent with the ICSG designation. The quoted narrative at the bottom of page 2.04.10-15 and top of 2.04-16, in Section 3.0, describes haylands with shallow soils and rock ledges. Narrative in Section 5.6 regarding 1987 Cropland designated areas describes "...two cropland areas in the central portion of the study area (western edge of the permit area) ...were not tilled after harvest the previous year and were allowed to volunteer barley and a host of annual and perennial weedy species" Narrative on the same page also notes that soils in the cropland area contain areas with shallow soils or boggy ground, and have low production potential for cropland. Please revise the narrative on page 2.04.10-15 to be consistent with the ICSG designation. 5A. There appears to be some overlap between the 1987 and 1999 study areas. No study boundaries were shown on Map 2.04.10. The boundaries are pertinent to the evaluation of vegetative production on the pre-mine fields. Furthermore, the aerial photo added as a layer to Map 2.04. 10 masks many of the labels. Please remove the aerial photo layer from Map 2.04.10. The aerial photo does provide good