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< Y recommendations in the November 16 letter. I was asked to make recommendations using different assumptions and within different contexts, and. As such, my two letters are not contradictory, as you assert. The next issue that needs some clarification is the designation of Prime Farmland within the New Horizon Mine Permit Boundary. The official source for making Prime Farmland designations is the NRCS National Soil Survey Handbook. The Soil Survey of the San Miguel Area, which covers the Nucla, CO area, is derived from the National Soil Survey Handbook. The San Miguel Soil Survey has been available to the public since 1988. Table 6 of the San Miguel Soil Survey lists Prime Farmland Soils within the San Miguel Soil Survey Area. Barx Fine Sandy Loam, I to 3 percent and 3 to 6 percent, are in. the Prime Farmland Soil list, and are considered Prime Farmland if irrigated. Prior to 2008, the only official Prime Farmland determinations made by NRCS field staff within the New Horizon Mine Permit boundary were two site-specific reviews conducted by Dean Stindt, NRCS District Conservationist, in 1992 and 1996 (attached). Both of these determinations were very specific as to their locations within the Mine Pen-nit boundary, and no other official Prime Farmland Determination was conducted by NRCS field staff until 2008. In the Background section of the Walsh report the following is written: "The New Horizon Mine mines coal under a DRMS permit. The permit defines soil handling procedures that have been followed by WFC. Prior to February 2008, the permit did not recognize any soil within the permit boundary as being "prime farmland" as defined in the CRMS regulations and by the National [Nlatural] Resource[s] Conservation Service (MRCS). Soil handling was consistent with the permit and the NRCS ruling prior to permit issuance that there were no prime farmland soils within the permit area." This last sentence is completely misleading and erroneous. Again, the NRCS never made an official ruling prior to permit issuance that. there were no prime farmland soils within the [entire] permit area. On the contrary, the San Miguel Soil Survey clearly identifies Prime Farmland Soils within the permit boundary. The other document most likely relied upon by Western Fuels regarding the existence of Prime Farmland Soils within the mine permit boundary is the "Order I Soil Survey for New Horizon Mine, Western Fuels - Colorado, LLC, Nucla, Colorado, March, 1998." conducted by Intermountain Resource Inventories Inc. In the Interpretations section of this soil survey (page 14), last paragraph, the following is written: 'Barx, irrigated soil is the second component in this map unit [Map unit 98E, Darvey- Barx Complex]. Barx, irrigated is a prime farmland soil in Colorado4. This soil falls within the criteria listed in the National Soil Survey Handbooks for prime farmland soil. However, in the Colorado Important Farmland Inventory page 3, "irrigated soils that have a pH higher than 7.4 are considered as having high conductivity and therefore are not considered prime" 4. Barx soil as used in this survey is not consider as not being prime farmland because the pH is higher than 7.4 in all horizons." 'Soil Survey o1' San Miguel Area, Colorado, Parts of Dolores, Montrose and San Miguel Counties 'Colorado important Farmland Inventory, MRCS Colorado National Soil Survey Handbook, ChaptLh• 657.5, Identilication of lmportant Farmlands. NRCS. Washington DC, 1996 Edition. I've underlined both occurrences of "not" in the last sentence. Obviously, this interpretation contains some inconsistencies. The problem arises because of the use of the "Colorado Important Farmland Inventory, NRCS Colorado." This document, which,has since been