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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 5 of 31 <br />41. This comment requested revision of confusing wording in Item 2 of Subsection 10.4. The item <br />narrative was revised, but the Division finds that the revised wording in the narrative could be <br />misinterpreted, due to usage of the term "prime farmland soils", where the term "prime <br />farmland" would be appropriate. The Division recommends that the narrative of Item 2, <br />following the first sentence, be replaced with the following: <br />These lands are owned by Morgan. Based on the fact that all requirements in the definition <br />(Rule 1. 04(95)) are met, the 107.96 acres of Morgan property (all Morgan property in the <br />permit area) is recognized to be prime farmland. As is seen from Map 2.04.9-1, some soils in <br />these fields are not prime, but all fields in this area are considered to be prime farmland. <br />Although Western Fuels mined the eastern portion of these areas prior to the prime farmland <br />designation, all lands on the Morgan property within the permit area that are disturbed by <br />mining will be restored to prime farmland standards. <br />4J. Resolved. This comment requested revision of the Subsection 16 "Topsoil Stripping <br />Procedures..." narrative, to more accurately describe color changes that differentiate salvage <br />lifts on the Morgan prime farmland area, and to reflect observations and recommendations made <br />during a joint DRMS/NRCS inspection in June 2010. The revised narrative is provided in <br />amended Subsection 16.4, and includes the requested modifications. <br />NEW ITEMS <br />The Division has the following additional comments based on a review of the amended materials in <br />Section 2.04.9. <br />4K. There are certain apparent discrepancies among text in Sections 2.04.9 and 2.05.4(2)(d), and <br />related maps 2.04.9-2, 2.05.4-4, 2.05.4-6, and 2.05.4-7, with respect to soil replacement. <br />a. The 3rd paragraph in Subsection 16 of 2.04.9, "Topsoil Stripping Procedures, states "all <br />topsoil backfilled thicknesses are shown on the [Map 2.04.9-2] for the entire permit area". <br />The wording "topsoil backfilled" is unclear; presumably topsoil replacement thicknesses" is <br />intended.. The information is not shown on Map 2.04.9-2; presumably Map 2.05.4-4 was the <br />intended reference. Please revise for clarity. <br />b. The terminology used in the first paragraph of Subsection 16.4 of Section 2.04.9 is <br />inconsistent with terminology used in other sections of the permit and needs to be changed <br />for consistency. Reference to "subsoil" and "topsoil (Lift A)" in the 3`d to last sentence of <br />the paragraph should be "Bench 1 subsoil substitute" and "topsoil (Mixed Lift)", <br />respectively. In the next to last sentence of the subsection, "Lift A" should be "mixed lift <br />topsoil" and "Lift B" should be "Bench 1 subsoil substitute". Please make these corrections. <br />c. Furthermore, in the first paragraph of 16.4, the Division requests WFC to strike all but the <br />first 3 sentences. The remainder of the paragraph has nothing to do with Topsoil Stripping, <br />and contains erroneous and misleading language. <br />d. The 3`d to last paragraph of amended Section 16.4 of 2.04.9 contains language that blurs the <br />distinction between planned stripping thicknesses and planned replacement thicknesses. <br />Specifically, the sentence which states that "...policies outlined above will provide <br />approximately 16 inches of Lift A and 36" of Lift B, which is a total of 52 inches, which is <br />more than the 48 inches desired by the NRCS" should be re-worded. We suggest the