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TDN Response <br />New Horizon Mine <br />April 23, 2010 <br />Page 7 <br />The currently approved production success standard for irrigated hayland is a technical standard based <br />on a combination of permit area landowner estimates, NRCS evaluation, and landowner production <br />records from 1987 and 1999, for alfalfa hayland first cutting production. Yield estimates and records <br />for the permit area landowners, and a June, 1998 letter from the NRCS supportive of a production <br />standard of 1.84 tons /acre /year, for 1st cutting irrigated hayland production, are included in <br />Attachment 2.05.4(2)(e) -2, of the permit application. Success for irrigated hayland production will be <br />demonstrated when the production mean based on sampling is not less than 90% of 1.84 tons per acre, <br />with 90% statistical confidence. Alternatively, success will be demonstrated when production based <br />on total harvest (1st cutting) is not less than 90 % of 1.84 tons per acre. <br />Other issues identified during the PR -6 review address the management practices to be undertaken on <br />the Morgan prime farmland property including land leveling, rock picking and fertilization. As <br />mentioned previously, another big issue is how many acres WFC will irrigate, not only on the Morgan <br />property, but other land parcels as well. <br />The Division issued an adequacy letter regarding PR -6 on January 22, 2010. A follow -up adequacy <br />letter was sent on April 6, 2010. WFC has not yet responded. WFC did request and the Division <br />granted an extension to the decision deadline from April 19, 2010 to June 18, 2010. <br />Prime Farmland Summary <br />The Division took appropriate action under its regulatory program to ensure protection of Prime <br />Farmlands. The Division's initial determination that the relevant area was not Prime Farmland was <br />reasonable and not arbitrary, capricious, or abuse of discretion. The Division's determination was <br />based upon NRCS documentation and analysis which supported the conclusion that these were not <br />Prime Farmlands. Pursuant to Division Rule 2.04.12, NRCS documentation provides an appropriate <br />guideline for determining whether Prime Farmlands are present. Thus, the Division had good cause <br />for its original negative determination. When the Division identified the error in the NRCS <br />documentation it took immediate and appropriate action to protect potential prime farmlands, by <br />requiring WFC to submit a TR addressing the soil removal and stockpiling. As required by TR -57, all <br />topsoil on the Morgan property will be handled as prime farmland soils with the capability of <br />irrigation. <br />SOILS RESOURCES <br />Permit Revision No. 5 Requirements. As explained in the prime farmlands section above, an Order <br />one soil survey was conducted for the PR -5 expansion area. The approved plan required a two -lift <br />topsoil salvage and replacement procedure for all soil map units, with the exception of two relatively <br />shallow upland soils which were not represented on the Morgan property. Soil map units with <br />associated salvage volumes by lift were shown on Map 2.04.9 -1. Topsoil salvage depths were listed in <br />Table 2.05.4(2)(d) -3. For the Darvey -Barx unit the mean salvage depth for Lift -1 was 1.4 feet and the <br />mean salvage depth for Lift -2 was 3.0 feet (Table Rev. 6 -18- 2001). Footnote 2 in the table states that <br />the Darvey -Bari soil resources will primarily be utilized in postmine irrigated pasture/hayland areas. <br />