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C-1981-008 July 23, 2010 <br />PR-06 Page 7 of 31 <br />4P. The last sentence of Item 1, Subsection 10.3, lacks clarity and improperly refers to prime <br />farmland as a land use. Please revise as follows: "If adequate water is available and other <br />definitional requirements are met, the subject area is classified as prime farmland." <br />4Q. Please cite the 6/27/08 NRCS letter regarding Begay Soil unit prime farmland determination <br />immediately following the second sentence of Item 3, Subsection 10.4. Include a reference to <br />the letter in Attachment 2.04.9-6. Also, please include appropriate NRCS letter reference at the <br />end of Item 4 (North Edge Benson West), and revise the reference to Attachment 2.04.9-10 at <br />the end of Item 5 (North Edge of Lloyd property), to properly reference Attachment 2.04.9-6. <br />4R. Please amend the paragraph regarding prime farmland status of Benson East areas, in Item 6, <br />Subsection 1.0.4, for clarity and accuracy. Specifically, please delete the statement that "none of <br />these areas were ever managed as prime farmland prior to mining", and the statement that "the <br />NRCS is not considering these areas prime farmland". Please add the following sentence to the <br />end of the paragraph: "These areas were mined and reclaimed in accordance with prior DRMS <br />determination that the areas were not prime farmland". <br />4S. The first paragraph (one sentence) following Footnote 5 to Table 2.04.9-2 is an outdated relic, <br />with reference to Lift B specifications that are no longer included in Table 2.04.9-2. Please <br />delete the outdated sentence. <br />4T. In the last paragraph of Subsection 11, following Table 2.04.9-2, the narrative states that <br />"...recommended topsoil salvage depths for each map unit are weighted averages of each major <br />component of the map unit...". However, in Table 2.04.9-3, the "weighted average" lift <br />thickness values for map units with multiple major soil type components appear to be simple <br />arithmetic averages, with no apparent weighting based on relative area of individual soil types <br />within a map unit. Also, the term "weighted average" was changed to "weight average", in the <br />table, for no evident reason (possibly a "global" typographical error). On the Table 2.04.9-8 <br />series, it also appears that individual sample lift thickness values were averaged, with no <br />weighting based on map units or component soil types within map units, although the calculated <br />averages are listed as "weighted averages". Please address these discrepancies and amend as <br />warranted. <br />4U. Table 2.04.9-3 uses the terms "Lift A" and "Lift B", while Table 2.04.9-4 uses "Lift 1" and <br />"Lift 2". Please revise the table(s) to use the Lift A and Lift B terminology consistently. <br />In amended Table 2.04.9-4, the material volumes listed for Material Lift 2, appear questionable. <br />For example, the Lift 2 volume for Map Unit 98A is 7 times as high as the volume for Lift 1, <br />even though Lift 2 thickness is only twice as high as Lift 1. For most of the other map units <br />listed, Lift 2 volumes are substantially less than Lift 1 volumes, even though Lift 2 soil <br />thicknesses are generally substantially greater than Lift 1. Please explain the apparently <br />erroneous values and amend as warranted. <br />The note beneath Table 2.04.9-4 states that, "the 1998 Soil Survey did not cover the entire <br />permit amendment area, therefore, acreages do not accurately represent the actual area of <br />disturbance. It appears that this comment refers to the southernmost portion of the western end <br />of the Morgan property, which is identified as unit 98E on Map 2.04.9-1. Please revise the