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SECTION 2.04.12 <br />PRIME FARMLAND INVESTIGATION <br />The soils mapping performed by the Natural Resources Conservation Service (MRCS) within the <br />boundaries of the proposed North Mine permit area is found on Map 2.04.9 -1, NRCS Soils Map. <br />Examination of the on line version of the "Soil Survey of San Miguel Area, Colorado - Parts of <br />Dolores, Montrose, and San Miguel Counties" contains a listing of designated prime farmland <br />soils mapping units on Table 6, Prime farmland. Examination of Map 2.04.9 -1, NRCS Soils <br />Map reveals that the NRCS has mapped a total of seven different soils mapping units as <br />occurring within the proposed North Mine permit area. One of these soils mapping units; 71, <br />Nyswonger silty clay loam, 1 to 4 percent slopes, occupies a total of 1.38 acres or about 0.43 <br />percent of the proposed mine permit area. The NRCS Soil Survey reports that this soils mapping <br />unit is designated as "prime farmland if irrigated." <br />There are two tracts mapped as corresponding to soils mapping unit 71, Nyswonger silty clay <br />loam, 1 to 4 percent slopes located within the boundaries of the proposed New Horizon North <br />Mine permit area. One tract of soils corresponding to soils mapping unit 71 is located in the very <br />southeast corner of the undisturbed area, just to the north and east of the Rice Tract. Another <br />small parcel of this soils mapping unit is found adjacent to Tuttle Draw in the proposed <br />equipment corridor area. In the discussion that follows, these tracts will be referred to as the <br />Rice tract and Tuttle Draw tracts, respectively. <br />Rice Tract <br />The location of this area, mapped by the NRCS soils mapping unit 71, Nyswonger silty clay <br />loam, 1 to 4 percent slopes. WFC submits that the soils on this site should not be considered as <br />prime farmland soils for the following reasons. <br />As documented on Map 2.04.10 -1, Permit Area Vegetation Map, the vegetation within this <br />NRCS soil mapping unit is all mapped as Sagebrush. Since this site is dominated by mature <br />Sagebrush plants, it is impossible for this site to satisfy the definition of "historically used for <br />cropland" since the site has not been used as cropland for anytime during the preceding 10 years. <br />Within the memories of Mr. Joe Garvey, the current landowner and Mr. Rex Case, both of whom <br />have lived nearby for over 60 years, this specific location has never been irrigated nor have <br />"crops" as defined in Section 1.04(71) ever been planted on this site. Consultation with Mr. <br />Lance Wade and Mr. Ross Gubka of WFC, who have worked on this mine since 1992, confirms <br />that neither WFC nor anyone else has planted crops on this site in the past 18 years. <br />In fact, the remaining undisturbed portion of soil mapping unit 71 found on this site, which is <br />north of the previous mining disturbance is up slope of the irrigation ditch rendering the physical <br />Section 2.04.12 Page 1 April 2011 <br />