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C- 1981 -008 August 25, 2010 PR -06 AR #5 Page 19 of 26 51. A typographical error in Subsection 2.1 was corrected as requested. Item Resolved 52. As requested, a reference to correspondence with landowners regarding postmining land uses was inserted in Subsection 3.0. Item Resolved 53. WFC provided the proposed irrigation plans in the letters to the landowners where irrigation is proposed. Item Resolved 53A NEW ITEM— The various letters to the landowners have been compiled in Attachment 2.05.4(2)(3) -8. An organized presentation of the letters would be both helpful and useful. The Division requests that the letters be organized into two sections within this attachment: • Lands east of 2700 Road (Staats, Moore, Benson, Goforth, San Miguel Power, Burbridge, WFC and Richards); and • Lands west of 2700 Road (Morgan, Lloyd, Benson and WFC). Please create a table of contents for this attachment, which lists each letter individually, by landowner, date and subject. 54. WFC has revised the discussion on irrigated parcels in subsection 3.0 of Section 2.05.4(2)(e) as follows. a. This concern dealt with information provided in Subsection 3.0 of 2.05.4(2)(e), regarding irrigation water requirements (acre per share ratios), and associated postmining land use plans for reclamation parcels west of 2700 Road. One question the Division has after reconsidering the information in this section regards an apparent discrepancy with respect to the irrigation requirements among the various parcels. The majority of the Morgan property would be irrigated by sideroll sprinkler irrigation, with a smaller portion to be irrigated by flood irrigation. The Morgans have agreed to provide the 62 shares of CCC ditch water (plus additional shares as needed to properly irrigate the entire 107.96 acres). Narrative in Item 4 of Subsection 3.0 states that MRCS calculated a ratio of 1.62 acres per share, for sideroll irrigation on the Morgan property. In Item 1 of the subsection, WFC references calculations based on NRCS design criteria to support a ratio of 1.03 acres per share for the Benson West irrigated pasture property. Item 2 of the subsection projects a ratio of 1.06 acres per share for the Lloyd property irrigated pastureland. The Benson and Lloyd property ratios are based on flood irrigation, which is less efficient than sideroll irrigation, which presumably is the main reason the ratios listed for Benson and Lloyd properties are significantly lower than the ratio NRCS calculated for Morgan sideroll irrigation. However, in Item 3 of the subsection, WFC projects a ratio of 1.62 acres per share for a small area of WFC cropland that would be flood irrigated. The Division requests explanation to support use of the 1.62 acre /share ratio for WFC flood irrigation (same ratio NRCS calculated for sideroll irrigation on Morgan property), rather than the lower ratio consistent with the Benson/Lloyd flood irrigation ratios. Alternatively, please revise the ratio if warranted. b. Previously resolved. 55 -59. Previously resolved.