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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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that the DRMS negative determination, the procedures involved in PR 05, TR-57, <br />or any other relevant approval, or the reliance on the erroneous soil sample by <br />WFC and by DRMS, singly or collectively constitute a violation of any applicable <br />statutes, rules, or regulations. The ultimate source of the misidentification of the <br />Prime Farmland soils on the Morgan Property was a typographical error in a <br />government-published reference source material (the Colorado Important <br />Farmland Inventory) that was used by the consultant who completed the soil <br />survey in 1998. The 1998 soil survey reached conclusions that were consistent <br />with soil surveys also completed in 1988, 1992, and 1996 concerning the same <br />or nearby lands. WFC's position on this issue is consistent with the <br />determination reached by the United States Department of the Interior, Office of <br />Surface Mining, in its interim response to Ms. Turner dated June 9, 2010, that the <br />terms of the WFC permit for the New Horizon Mine "properly implement the <br />requirements of the Colorado regulatory program, and that mining and <br />reclamation of the Morgan property located within the permit boundary has been <br />conducted in accordance with the approved permit" (Attachment 8 at page 2). <br />Comment No. 7: <br />2.04.3-6 What abandoned cropland? What abandoned irrigated cropland? <br />What abandoned irrigated Farmland? <br />"'Improvements are generally limited to land leveling." WHAT A LIE. Another <br />cut to the farmer. They don't even know how hard we work to get these farms <br />in the conditions that they. were before the mine entered the properties. <br />Constant rock picking, constant fertilizing, constant leveling and <br />cultipacking, rotations, constant removing weeds and unwanted growths, <br />even pastures require hours of maintenance. Constantly fighting rodents <br />and weevils and everything. <br />"Induced wheat grasses." <br />What induced wheat grasses which are actually a part of dryland mixes. Not <br />irrigated pastimes and haylands. <br />WFC Response: <br />Much of this comment is unintelligible. The comment regarding improvements <br />appears to rest on a misunderstanding of the term "improvements," which refers <br />only to buildings and structures, not soil amendment or other farming practices. <br />Correctly interpreted, the statement on page 2.04.3 - 6 is accurate. <br />Comment No. 8: <br />2.04 3-7 "Historic land use." ALL Lies 1.04(71) Land use is what the land is <br />used for NOT the vegetation cover. Most all of NH2 has been HISTORICALLY <br />used as cropland. 1.04(60) lands that have been used for cropland ANY 5 <br />out of 10 or more years preceding the acquisition 1.04(a) cropland is land
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