2011-08-04_ENFORCEMENT - C1981008 ‎(4)‎

• Permit No: C1981008
• IBM Index Class Name: ENFORCEMENT
• Doc Date: 8/4/2011
• Doc Name: OSM Technical Review of PR6 Prime Farmland Yield - Morgan Property
• From: OSM
• To: DRMS
• Email Name: SB1
• Email Name: DAB
• Email Name: MLT
• Media Type: D
• Archive: No

Field
Date
Acres
Bales
Bale Wt
(lbs)
lbs/ac
(tons /ac)
Notes
Primary Soil Map
Unit*
1
6/25/99
21
2034
88
8523
Alfalfa
98E
(4.26)
Unit*
2
7/1/99
28
394
81
1140
Not irrigated in
98E
2
7/4/99
11
517
84
(.57)
1999, Grass?
98D
3
7/1/99
1
21
87
1827
Sub - irrigated in
98D
(.91)
1999, Grass?
Field
Date
Acres
Bales
Bale Wt
lbs /ac
Notes
Primary
(lbs)
(tons /ac)
Soil Map
Unit*
1
7/3/99
20
1024
86
4403 (2.2)
Grass?
98D
2
7/4/99
11
517
84
3948
Grass?
98D
(1.97)
2.04. -18 and Exhibit 2.04.10 -1
*An OSM visual estimated comparison between the Soil Baseline Map (2.04.9 -1) and Exhibit 2.04.10 -1 suggests that all but a small percentage of Field 1
is Barx 98E prime soils, w'th the remaining area being 98D non prime cols; all of Field 2 appears to be Barx 98E prime soils; and all of Field 3 appears to
be 98D non prime soil. It 's noted that a first cut 8,523 Ibs /ac for a, presumably irrigated, alfalfa crop in Field I, on 98E Barx Prime Farmland soils, is
equal to a first cut yield of 4.26 tons /ac.
OSM was unable to discern if Fields 2 and 3 referenced in Table 2.04.10 -18 were alfalfa or
grass hay; but assumes they were grass hay.
Data taken from the permit, Table 2.04.10 -18 and Exhibit 2.04.10 -1 shows the following for two fields on the Johnson
*An OSM visual estimated comparison between the Soil Baseline Map (2.04.9 -1) and Exhibit 2.04.10 -1 suggests most of the soil on both of Johnson's
fields is 98D, with some minor inclus'ons of 98F, and 9813. As with fields 2 and 3 for the Morgan Property; there was no information as to what was
grown on Johnson's fields 1 and 2 and so hay grasses are assumed. As reported in the text, Johnson's fields were irrigated and cut twice. Thus, assuming
primarily 98D Bowbac - Bowdish complex soils of irrigated hay grasses with 2 cuttings, one can calculate an approximate weighted yield, based on this
data, of 2.12 tons /ac.
Section 2.05.4(2)(e) of the permit, subsection 5.5.2, "Standard for Production for Irrigated Cropland
(formerly Irrigated Hayland)" on pages 44 -45: states a yield standard of 1.84 tons per acre. This was
based upon interviews with local farmers in the area and is for only one cutting, not the entire annual
yield:
"The success standard for WFC 's irrigated cropland will be based upon 1st cutting production only
so our yield can be easily compared with the local farmers. WFC personally contacted three of the
larger farms (Mel Staats, Frank Morgan, and Zene Weimer) that surround NH2 for their first cutting
production figures in irrigated cropland fields. See Attachment 2.05.4(2)(e) -3). They gave us their
estimates of first cutting crop yield for irrigated cropland in the Nucla area. Since these farmers had
no practical way to weigh the bales the reported yields were based on nondried bale weights. The
approved standard for Irrigated Cropland previously called Irrigated Hayland was the average 1st
cutting yield from these three farmers. Based on this a 1st cutting production of 1.84 tons per acre is
the target yield at Neils Horizon Mine. No drying is done for attaining this standard since none was
done by the 3 farmers used to determine their yields which is the basis of their letters and
consequently the basis of the standard. Drying was employed to determine the 1987 data collected
shown in Table 2.05.4(2)(e) -4, but this data was not used to determine the standard of 1.84 tons per
acre. The farmer letters in Attachment 2.05.4(2)(e) -3 were the basis for the standard." •
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