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Topsoil Resource Management <br />15. The Objectors object to what happened to the topsoil initially removed from the <br />Morgan property. Prior to the February 2008 prime farmland determination, topsoil was <br />stripped in a single lift then placed in its final location. This topsoil management method <br />was approved in the permit. A portion of the Morgan property (approximately the <br />easternmost 20-acres) will be reclaimed using mixed topsoil on top of a suitable subsoil. <br />16. The topsoil on the Morgan property's remaining 88 acres will be replaced in two <br />lifts. Soil placement is dictated by a strict plan for location, type, and thickness contained in <br />Section 2.05.4(2)(d) of the permit revision. <br />17. All the topsoil placed on the Morgan property (and all areas designated as prime <br />farmlands) is tested for suitability based on the thresholds approved in a previous technical <br />revision and expanded upon in PR-6. The tests ensure the reclaimed topsoil will be a <br />sufficient growth medium for irrigated cropland. See Sections 2.05.4(2)(d) and 2.05.4(2)(e) <br />of PR-6. The process prepares topsoil for success as a vegetative growth medium. <br />18. The NRCS reviewed the soil reclamation and re-vegetation practices described in <br />PR-6. A NRCS resource conservationist states in June 30, 2010 and October 1, 2010 letters <br />"I am in support of the practices listed in their detail." <br />19. Overall, the topsoil redistribution, soil suitability, and topsoil reconditioning will <br />conform to the exacting requirements of the applicable rules. <br />Prime Farmlands <br />20. The Objectors have raised numerous objections regarding the classification and <br />handling of the Morgan property's topsoils. Many of the objections concern events that <br />occurred prior to prime lands determination in February 2008 and prior to Western Fuels <br />submitting PR-6. These events are beyond the Board's jurisdiction. <br />21. For the original permit area east of 2700 Road, the NRCS reviewed the Barx soils <br />and visited the site. The NRCS determined and wrote letters in 1992 and 1996 stating that <br />the Barx soil was not prime farmland. These letters are located in PR-6 Attachment 2.04.9-6. <br />22. In January 2008, the NRCS reevaluated the Barx soil on the Morgan property. In <br />February 2008, the NRCS determined that it should be considered prime. Moving forward, <br />the Morgan property's topsoil was considered prime farmlands and was handled accordingly. <br />23. The entire Morgan property was then designated as prime farmland.I As soon as <br />the prime farmland determination was made the topsoil management practices changed to <br />those required for prime farmlands. The topsoil stripping from undisturbed ground on the <br />Morgan property occurred in two lifts. The materials were stockpiled separately for <br />replacement on the Morgan property. <br />' Although the entire Morgan property was designated as prime farmlands, approximately 20 acres does not contain <br />Barx soil - and was not considered prime farmland in the pre-mine study. <br />Western Fuels <br />Order <br />C-1981-008