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procedure developed in TR -57 (two -lift removal) with additional detail added to the topsoil <br />handling plans to satisfy Colorado mined land reclamation requirements. <br />It is important to note that although the entire Morgan property in the permit was designated as <br />prime farmland, approximately 20 acres of the 108 acres was not Barx soil and were not prime <br />farmland soils in the pre -mine study. This is approximately the same amount of acreage on the <br />eastern portion of the Morgan property that is receiving the mixed topsoil over Bench 1 material. <br />See, Map 2.04.9 -1 (contained in WFC Exhibit 5) . Thus, Rule 4.25.2(4) will be satisfied. <br />In PR -06, considerable time was spent in working up a reclamation plan for the prime farmland <br />areas, with year by year plans for the entire 10 year bond release period. Detailed handling and <br />soil reconditioning procedures were also developed. These items were done with input from all <br />four parties, NRCS, DRMS, the Morgan family, and WFC. <br />Topsoil placed on the eastern 20.01 (Zones 1 & 2 on Map 2.05.4 -6) acres of the Morgan property <br />prior to the prime farmland determination was tested for soil suitability as part of the revised <br />topsoil management plan developed in TR57. These standards were approved by DRMS as part <br />of TR -57 (see Table 2.05.4(2)(d) -1 from TR -57 Section 2.05.4(2)(d) ( WFC Exhibit 18) ). As part <br />of PR -06, DRMS required WFC to provide more detail on the soil and spoil suitability criteria in <br />order for the information to be clearer for each soil material type. The requirements were split <br />into two tables (Table 2.05.4(2)(d) -IA and -1B from PR -06) with further suitability requirements <br />for either soil on non -prime farmland areas or spoil buried beneath soil and subsoil on any area. <br />See, WFC Exhibit 6 . As part of the soil suitability testing, a remediation plan was also <br />implemented to remove unsuitable soil or subsoil substitute from the soil medium. As discussed <br />above, topsoil placement on Zones 3 and 4 of the Morgan property will be in excess of Prime <br />Farmland and NRCS requirements. <br />In order for WFC to be released from reclamation bond, it must achieve a first cutting production <br />of 1.84 tons /acre for the final three years of the 10 -year reclamation period. This production <br />value was determined via discussions with the Morgan family, area farmers, and the local NRCS <br />representative, as shown in Attachment 2.05.4(2)(e) -3 (WFC Exhibit 1) . Thus, WFC has a <br />vested interest in ensuring that the productivity targets will be met following reclamation. <br />C. Summary <br />In summary, once the prime farmland designation was made, WFC did everything possible to <br />immediately address the topsoil handling requirements and develop a solid reclamation plan for <br />the entire Morgan property, based on cropland with prime farmland soils. PR -06 contains a plan <br />to achieve these goals, and the productivity standards necessary to achieve bond release are those <br />applicable to Irrigated Cropland on Prime Farmlands. <br />