2013-01-25_GENERAL DOCUMENTS - C1981008 (2)

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recommendations in the November 16 letter. 1 was as to mato Ipoornmeudations using different assumptions and within different contexts, and as snob, my two letters arena contradictory, as yen assert. The next issue that needs some clarification is the designation of Fume Farmland within the New Horizon MinePermit Boundary. The ofFicial source for making Prime Farmland designations is the MRCS National Soil Survey Handbook. The Soil Survey of the San Miguel Area, which covers the Nacre, CO area, is derived from the National Soil Survey Handbook The San Mig%tal Soil Survey has been available to the public since 1988. Table 6 of the San Miguel Soil Survey lists Prince Farmland Sorbs within the San Miguel Soil Survey Area. Banc l=ine Sandy Loam, I to 3 percent and 3 to 6 percent, are in the Prime Farmland Soil list, and are considered Prime Farmland if irrigated. Prior to 2008, the only official Prime Farmland determinations madeby NRCS field staff within the New Horizon Mine 'Permit boundary were two site- specific reviews conducted by Dean Stindt, NItCS Distriet Conservationist, in 1992 and 1996 (attached). Both of these determinations were very specific as to their locasions within the Mine Permit boundary, and no other official Prime Farmland Determination was conducted by MACS field staff until 2008. In the Background section of the Walsh -report the following is written: -rho New Horizon Mine mines coal under a DRMS permit. The permit defines soil handling procedures that have been followed by WFC. Prior to February 2005, the permit did not recognize any soil within the permit boundary as being "prime farmland" as defined in the CRMS regulations and by the National (Natural) Resouree[s) Conservation Service (NRCS). Soil handling was consistent with the permit and the li CS raking prior to permit issuance that there were noprime farmland soils within the permit area." This last sentence is completely misleading and erroneous. Again, the NP-CS never made an official ruling prior to permit issuance that there were no prime farmland soils within the [entire) permit area. On the contrary, the San Miguel Soil Survey clearly identifies Prime Farmland Soils within the permit boundary. The other document most likely relied upon by Western Fuels regarding the existence of Prince Farmland Soils within the nine permit boundary is the "Order I Soil Survey for New Horizon Mine, Western Fuel s — Colorado, LLC, Nude, Colorado, Merck 1998," conducted by Intermountain Resource ttrveatories Ina lathe Interpretations section of this Soil survey (page 14), last paragraph, the following is written: :`Bari, irrigated soil is the second component in this map unit [Map unit 98B, Darvey- Barx Complex]. Barr, irrigated -is a prime farmland soil in Colorado This soil falls within the criteria listed in the National Soil Survey Handbook for prime farmland so13. However, in the Colorado Important Varealani Inventory page3, "irrigated soils that have a pH higher than 7.4 are considered as having high conductivity and therefore arc riot considered prime Bari soil as used in this survey is lzot_ consider ash being prime farmland because the pH is higher than 7.4In all horizons." 'sot sw,tyortsli Miwac] Area. Colorado. farts of Dolons. yonrmsnaad gait )611+'103et Grades 'Colorado Im ?ortaatFarmlaid 1a"tastory. MRCS Colorado 'piaslor st Soil Sunw limsduook. Ct opter 657.5.14-at4Gaim oflnprrlms FavasaM. }1RGS. Wa■td,utor, DC 1996 Educes. I've underlined both occurrences of "not" in the last sentence. Obviously, this Interpretation ' contains some inconsistencies. The problem arises because of the use of the " Colorado Important Farmland Inventory, NRCS Colorado." This document, which.has since been PLTF 001048 8'd Z89L-i798-0L6 .ieuanl ueoor