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2010-07-29_REVISION - C1981008
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2010-07-29_REVISION - C1981008
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Last modified
8/24/2016 4:17:00 PM
Creation date
7/29/2010 12:54:02 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
7/29/2010
Doc Name
Response to Adequacy Review No. 3 (Response to Morgan Property Issues)
From
Western Fuels Colorado
To
DRMS
Type & Sequence
PR6
Email Name
SB1
MLT
Media Type
D
Archive
No
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wonder that we are even here. <br />WFC Response: <br />WFC incorporates its response to Comment No. 6, above. Though no longer <br />relevant, for the sake of accuracy in the record, WFC does not agree with the <br />characterization of the 1988, 1992, or 1998 soil surveys, the reports of which are <br />in the record and speak for themselves. WFC will not respond to the personal <br />attacks, profanity and inflammatory statements contained in this Comment. <br />Comment No. 17: <br />2.04 9-16 "Part of the reason for the reversal was due to a typographical <br />error in a previous NRCS documentation." First off THE OFFICIAL <br />REFERENCE IS NOT NRCS OR THE COLORADO FARM LAND INVENTORY. <br />THE OFFICIAL REFERENCE IS THE NATIONAL SOIL SURVEY HANDBOOK <br />WHICH WAS DOCUMENTED TO BE PRIME FARMLAND IN 1998 and was <br />documented as being PRIME soils in 1988, 1992, 1996, and 1998. To use <br />any other documentation or less documentation that what is required by <br />Federal and State laws is not acceptable and everyone is getting sued for <br />that. All rules, regulations, Federal and State have been violated here. <br />SECOND, even in the Colorado Farmland Inventory the typo error was on <br />one page and on the prior it also stated it was prime farmland. Federal and <br />State laws say that it must be PROVEN BEYOND A DOUBT, NOT JUST A <br />TYPO ERROR IN ONE PIECE OF PAPER!!!! NRCS SHOULD HAVE BEEN <br />CONSULTED AT THAT TIME AS WELL AS THE USDA and it was mandatory <br />by law that the STATE also do a thorough investigation. NONE OF THIS <br />WAS DONE> HOW DO THEY GET THEIR PERMIT RENEWED???? <br />WFC Response: <br />WFC incorporates its response to Comment No. 6, above, and again disagrees <br />with the characterization of the prior soil surveys relevant to the permit process, <br />the reports of which are in the record and speak for themselves. WFC is not <br />intimidated by, but will not respond to the threats of legal action except in an <br />appropriate forum. <br />Comment No. 18: <br />Page 2.04.9-16 The Rules and regulations do not say this. Prime Farmland <br />exists if it has been historically used as cropland NO Water is mentioned, no <br />management is mentioned. They are taking the rules and laws out of <br />context, again. It must have less than 6 % slopes, it must have a growing <br />season of at list 90 days, no water is mentioned, no management no <br />production yields, just read the laws and the rules. It must have very few <br />rocks in the soil, it must have an adequate and dependable WATER SUPPLY
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