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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 3 of 31 <br />4A-3. The definition given for "Cropland-Irrigated Small Grain (ICSG)" correctly notes that that <br />vegetation observed during the baseline study in 1987, included volunteer barley, but a broader <br />description addressing the presumed historic use would be appropriate, such as the following: <br />"These areas were historically used for small grain production. Within the permit area, soils <br />where this type is delineated are generally shallow and boggy, and not considered to have a high <br />crop production potential. During the baseline sampling year (1987) it was noted that the two <br />ICSG areas were not tilled after harvest the previous year and were allowed to volunteer barley, <br />along with annual and perennial weeds". Please revise the definition. <br />4A-4. On the amended Pre-Mine Land Use Map (2.04.3), the Irrigate Pasture Swale (IPSW) land use <br />category was inadvertently omitted from the Land Use Areas acreage table included on the map. <br />In addition, the IPSW designation was not denoted on the delineated map areas where it <br />presumably should have been indicated, along with the appropriate acreage. Finally, the <br />irregular gray line along the inside perimeter of the permit boundary is presumably the <br />Disturbed Area perimeter, but this is not indicated in the map legend. Please revise the map to <br />properly identify and list the pertinent acreages for the IPSW category (both on the map table <br />and within the map itself), and to identify the Disturbed Area boundary line in the map legend. <br />Rule 2.04.9 Soils Resource Information <br />4B. In Adequacy Review No. 3 (PAR-3), the Division requested that WFC review the entire section <br />to remove outdated or incorrect information, and to identify and explain any outdated/erroneous <br />information that is being retained for historic purposes. The WFC response table does not <br />provide any detail, merely states "See revised Section 2.04.9". We have the following <br />comments. <br />a. Narrative in the first paragraph of amended Subsection 10.1 indicates that the version of the <br />National Soil Survey Handbook Chapter 657.5, which provides the USDA definition and <br />criteria for prime farmlands (Attachment 2.04.9-4), as well as information from the <br />Important Farmland Inventory for Colorado (Attachment 2.04.9-5) "contain erroneous <br />data". Please clarify in the text that these outdated documents are included for historical <br />purposes only, and please include a footnote on the cover page of each attachment stating <br />that the documents are outdated and included for historical purposes only. Finally please <br />obtain a copy of the current National Soil Survey Handbook Chapter 657.5 USDA definition <br />and criteria for prime farmland, and include the current dated copy of the document as an <br />attachment to the permit. <br />b. Also in the first paragraph of amended Subsection 10. 1, narrative notes that the <br />"data ... found to be erroneous" were revised by the NRCS in 2008. Please include a text <br />reference to the subject 2008 NRCS letter, and reference the permit attachment (2.04.9-6) <br />where it can be found. <br />4C. Please see question 14. below. <br />4D. The Division requested additional documentation and explanation regarding an October 1992 <br />NRCS negative prime farmland determination from Dean Stindt, NRCS District Conservationist <br />at that time, for a portion of the permit area. WFC provided the amended narrative in Subsection <br />10. 1, and provided a copy of an NRCS soil survey map with the 1992 permit boundary for the