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Draw portion of the proposed equipment corridor cannot be considered as prime farmland soils <br />similar reasons. Within the memories of Mr. Jim Williams who grew up on a property on this <br />site and spent nearly 50 years of his life living on this land, and who still retains an interest in <br />some of the coal rights in the area and Mr. Herb Enstrom, who lives immediately to the south of <br />the site and has lived on this land for more than 70 years, the lands corresponding to soils <br />mapping unit 71 in Tuttle Draw have never been irrigated nor have crops ever been planted on <br />this site. <br />According to Map 2.04.10 -1, Permit Area Vegetation Map, the vegetation within this NRCS soil <br />mapping unit in the vicinity of the Tuttle Draw equipment corridor crossing is largely mapped as <br />Sagebrush. Since this site is dominated by mature Sagebrush plants, often three to five feet tall, <br />it is impossible for this site to satisfy the definition of "historically used for cropland" since the <br />site has not been used as cropland for anytime during the preceding 10 years and there is no <br />evidence that it has ever been used as cropland. That small portion of the site that is not <br />dominated by Basin Big Sagebrush consists of the riparian fringe, dominated by wetland <br />vegetation and open waters of the stream channel in Tuttle Draw. Consultation with Mr. Lance <br />Wade and Mr. Ross Gubka of WFC, who have both 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 />Most of soil mapping unit 71 found on this site, is between four and six feet higher in elevation <br />than the waters flowing in the stream channel of this site. There is no evidence of any irrigation <br />ditches, abandoned or active, nor is there any evidence that the native vegetation has ever been <br />cleared for agricultural purposes. WFC submits that given the elevation of the lands on this site, <br />it impossible for the planted agricultural vegetation to be subirrigated with any degree of <br />dependability. Examination of the existing vegetation reveals that there is a narrow riparian <br />fringe immediately adjacent to the flowing waters in Tuttle Draw but that this fringe has never <br />been cropped and the vegetation is so dense, especially the salt cedar, that it would be impossible <br />for any cropping to have occurred in this area in the preceding 10 years. Beyond the riparian <br />fringe and narrow band of salt cedar, the remaining flood plain benches are dominated by Basin <br />Big Sagebrush and Rubber Rabbitbrush. The presence of these species and a lack of any <br />herbaceous understory that could be considered to be subirrigated makes it impossible to <br />conclude that this site is subirrigated an any "dependable" fashion to facilitate the production of <br />agricultural crops in this area. <br />Examination of NRCS aerial photographs as early as 1973 clearly show the site was not irrigated <br />at that time and numerous mine generated aerial photographs between 1980 and 2008 establish <br />that there is no evidence that this site was ever irrigated during this time period. The NRCS <br />1973 Land Use Map clearly shows that there was no irrigation of this site when mapped in 1973. <br />Given the very narrow width of the existing floodplain and limited extent of these floodplain <br />benches along with the relatively steep side conditions of this site, render it impossible for this <br />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 />Section 2.04.12 Page 3 April 2011 <br />