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The remaining 88 acres is designated for topsoil placement in 2 lifts. In Zone 3, two -lift topsoil <br />will be placed over Bench 1 material below, in excess of Rule 4.25.4(1) and the NRCS <br />requirements. See, WFC Exhibit 23 . In Zone 4, a total of 58" of separated A -lift and B -lift <br />topsoil will be used, again in excess of the requirements of Rule 4.25.4(1) and the NRCS <br />requirements. As required by the prime farmland regulations, each of the two lifts of soil on <br />Prime Farmland is stockpiled separately. Topsoil replacement on the Morgan property is dictated <br />by a strict plan for location, type, and thickness contained in Section 2.05.4(2)(e) of PR06 ( WFC <br />Exhibit 1). DRMS has approved of these topsoil placement procedures, which were constructed <br />with extensive input from NRCS. The details of this plan are shown on Map 2.05.4 -6 ( WFC <br />Exhibit 8 ) for the Morgan property <br />The reconditioning of topsoil as part of the preparation process described in Exhibit G to <br />Sections 2.05.4(2)(d) ( WFC Exhibit 6) and 2.05.4(2)(e) ( WFC Exhibit 1) will prepare <br />stockpiled topsoil for success as a growth medium for vegetation. Topsoil stockpiled over an <br />extended period of time requires reconditioning to return its growth medium potential. This is <br />one of the reasons that topsoil is typically not stockpiled once it is stripped, but placed directly <br />on areas in reclamation. All topsoil placed on Prime Farmland areas (the Morgan property) is <br />tested for suitability based on the thresholds approved in TR -57 and expanded upon in PR -06. <br />These tests insure that the topsoil used in reclamation will be sufficient as growth medium for <br />irrigated cropland. <br />C. Summary <br />Topsoil redistribution, soil suitability, and topsoil reconditioning will conform to the <br />requirements of the applicable rules including Prime Farmlands requirements. In addition, at the <br />Morgans request, WFC has agreed to replace all Bench 1 material from the Morgan property <br />back on the same property, though this is not required by the rules. <br />III. Hearing Issue No. 3 - Prime Farmlands <br />A. Overview <br />The most important Prime Farmland rules are contained in Rules 2.04.12, 2.06.6, and 4.25. <br />These detailed rules set forth requirements for pre- mining investigation, which was done prior to <br />PR -05 and consisted of a comprehensive soil survey completed by Jim Irvine of Intermountain <br />Resources, completed in August of 1998. This survey determined that the Morgan property was <br />not Prime Farmland. See, WFC Exhibit 29 and 21 -A . However, this conclusion was reversed <br />by NRCS in January 2008 based on new data. Map 2.04.9 -1 (WFC Exhibit 22) shows the soil <br />baseline as revised to reflect the 2008 determination. WFC immediately began mining <br />operations in compliance with the Prime Farmlands operational rules in 4.25, even before they <br />were required in TR -57, the minor permit revision that formally implemented the Prime <br />Farmlands requirements. PR -06 requires all operations and reclamation on the entire Morgan <br />Property to conform to Prime Farmlands standards. <br />The applicable standards are as follows. First, Rule 4.25.2(3) requires that "[r]evegetation <br />success on prime farmlands shall be measured upon the basis of comparison of actual crop <br />