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On May 18, 2010, the Director of the Office of Mined Land Reclamation, David A. Berry, sent <br />WFC a letter identifying nine critical permit defects that had to be addressed in the PR-6 <br />application. <br />On May 25, 2010, WFC submitted a response package to the Division's preliminary and <br />supplemental adequacy review letters and David Berry's letter. Following a detailed <br />examination of the response, the Division issued Adequacy Review No. 3 on June 22, 2010. In <br />this adequacy review, the Division noted a number of outdated, conflicting and inconsistent <br />sections within the permit. <br />WFC submitted their response to the third adequacy review on July 2, 2010. Several sections of <br />the permit were substantially reorganized with this version, resulting in a more cohesive and <br />consistent document. <br />The Division issued Adequacy Review No. 4 on July 23, 2010, and WFC produced a response <br />package on August 10, 2010. This response answered many of the outstanding issues; however, <br />permit inconsistencies and adequacy concerns remained. <br />On August 13, 2010 WFC sent a letter to David Berry regarding land owner coordination with <br />respect to PR-6. David Berry responded to the WFC letter on August 20, 2010. <br />On August 25, 2010, the Division issued Adequacy Review No. 5. WFC submitted their <br />response to this letter on September 22, 2010. <br />During the adequacy review process, numerous changes were proposed by WFC to resolve the <br />objections and concerns raised during the public comment periods. WFC consulted with <br />landowners during the process and provided the landowners with the company's proposed plans <br />for reclamation. Landowner consultations and correspondence is found in Attachment <br />2.05.4(2)(e)-8 of the permit. <br />With respect to the concerns regarding irrigation, WFC evaluated how many shares of CCC <br />Ditch water each landowner has and proposed a reclamation plan using NRCS design criteria for <br />the acre/share ratio for post mine irrigated pastureland areas using both sideroll irrigation and <br />flood irrigation. The irrigation designs are in Attachment 2.05.4(2)(e)-7, 8, 9 and 10. The <br />discussion on irrigated parcels is in subsection 3.0 of Section 2.05.4(2)(e). WFC also revised the <br />regrading plan to ensure that irrigation can be restored on those historically irrigated lands in the <br />future, if sufficient water becomes available. <br />On the Morgan Property, WFC has consulted with the NRCS to prepare the reclamation plan for <br />the prime farmlands. WFC consulted with the Morgans as required by the Act although <br />differences may still exist. WFC is proposing to irrigate all 107.96 disturbed acres on the <br />Morgan property, all of which have been designated Prime Farmland. WFC will return all <br />Bench 1 overburden material, and all Lift A and Lift B topsoil removed from the Morgan <br />property back to the Morgan property. Each lift will be sampled for soil suitability as it is <br />replaced. The field will be planted using the alfalfa seed variety requested by the Morgans. A <br />plan for field maintenance and crop replanting is addressed in the permit. A reference area will <br />8