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conditions impossible for irrigation. Examination of NRCS aerial photographs as early as 1973 <br />show the site was not irrigated at that time and numerous subsequent aerial photographs show no <br />evidence of the site ever being irrigated. The NRCS 1973 Land Use Map, clearly shows that <br />there was no irrigation of this site at that time. <br />The slope conditions of this render it impossible for this site to qualify as a prime farmland soil. <br />According to Section 2.04.12 (2)(b) a site cannot be considered to be a prime farmland soil if <br />"the slope of the land is 6 percent or greater ... " A detailed map of this site is found on Map <br />2.04.12, Rice Tract Prime Farmland Soils Map. This map shows that of the 0.94 acres of the site <br />mapped by the NRCS as corresponding to soils mapping unit 71, Nyswonger silty clay loam, 1 to <br />4 percent slopes; virtually the entire site has slopes greater than 4 percent, which is the upper <br />most slope limit for this soil mapping unit and 87.2 percent of this site has slopes greater than 6 <br />percent which is the upper most slope allowable for potential prime farmland soils in Section <br />2.04.12(2)(b). Of the remaining area, consisting of 0.12 acres or 12.3 percent of the area, the <br />slopes are less than six percent but since this site has never been historically irrigated or planted <br />to crops, it cannot be considered to be a prime farmland soil. The placement of three randomly <br />located slope measurements on the site reveals that two of the transects had slopes of 10 percent <br />and the other site, had a slope of 8 percent. These site specific slope measurements make it <br />impossible for this site to be considered as a prime farmland soil. <br />In the evaluation of the soils' characteristics of this site, WFC dug one backhoe soil pit to a depth <br />of more than six feet within the boundaries of the area mapped by the NRCS as corresponding to <br />soils mapping unit 71, Nyswonger silty clay loam, 1 to 4 percent slopes. Our evaluation of this <br />site reveals that the actual soil on this site is, based upon the descriptions found in the Soils <br />Survey, the soils on this site corresponds to the Pinon phase of NRCS soils mapping unit 77, <br />Pinon - Progresso loam, 3 to 12 percent slopes. A detailed profile description of this soils pit and <br />photograph, which corresponds to soils test pit R -69, found in Section 2.04.9 documents that the <br />NRCS mapping in this area is in error. Examination of the NRCS soils mapping unit <br />descriptions and typical soil profile descriptions confirm this error. According to the soils <br />mapping unit description, 71, Nyswonger silty clay loam, 1 to 4 percent slopes is found on <br />"alluvial fan, valley floor and terrace landforms," that the parent material of these soils is <br />"alluvium" and that the slope ranges from "1 to 4 percent." None of these conditions are <br />associated with this site. WFC therefore, concludes that the NRCS soils mapping of the area <br />designated as soils mapping unit 71 on the Rice Tract is in incorrect for at least three reasons. <br />The land form of the site, the parent materials and slopes do not correspond to the NRCS <br />definitions. <br />Tuttle Tract <br />As shown on Map 2.04.9 -1 NRCS Soils Map, lands corresponding roughly to the floodplain of <br />Tuttle Draw have been mapped by the NRCS as belonging to soils mapping unit; 71, <br />Nyswonger silty clay loam, 1 to 4 percent slopes. The NRCS reports that this soil mapping unit <br />is designated as "prime farmland if irrigated." A detailed blow up of this site is found on Map <br />2.04.12 -2, Tuttle Draw Prime Farmland Soil Map. WFC submits that the soils on the Tuttle <br />Section 2.04.12 Page 2 April 2011 <br />