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and areas to the east and south in the states of Kansas, Missouri, Oklahoma, Texas <br />and also southern Arizona. <br />11. Update regarding prime farmlands. <br />NECC Response: <br />Text on pages 2.04 -51 and 52 has been revised. A new soil survey was obtained <br />for the greater New Elk mine area including the area of expansion east of the <br />current RDA. This soil report should be included in Exhibit 14 of the permit <br />application. In the report, under the heading "interpretive group" for each soil <br />type, a determination is made regarding whether the soil is prime farmland soil. <br />No soil in the New Elk area is considered prime farmland, with the possible <br />exception of irrigated soils found adjacent to the New Elk mine that are not <br />currently disturbed nor proposed for disturbance by NECC. It should be noted <br />that previous correspondence the SCS for the Golden Eagle permit #C- 1981 -013 <br />indicate that a limiting factor in determining whether a candidate soil can be <br />considered prime farmland in the New Elk and Golden Eagle is the "short <br />growing season ". This permit text narrative is also present on approved page <br />2.04 -3 of the New Elk permit application. <br />12. Page 2.05 -27i needs removed. <br />NECC Response: <br />The text has been corrected to eliminate any duplicative text. <br />13. Page 2.05 -28 referencing Figure 10. <br />NECC Response: <br />The permit text has been corrected to remove reference to Figure 10. <br />14. Reference areas. <br />NECC Response: <br />TR -68 proposes to change the post- mining land use to rangeland in accordance <br />with the new (proposed and pending approval) coal rule changes. The post - <br />mining land use for the New Elk mine will be rangeland. NECC has control over <br />the rangeland reference area at the Golden Eagle mine as per the letter included in <br />Exhibit 15 dated 11/2/1999. This letter grants NECC the right of entry to the <br />reference area after the GE permit is terminated. NECC will ensure that the <br />reference area is marked. Permit text on revised page 53 includes the commitment <br />to mark the reference area. Text regarding the land use change as proposed and <br />changes to the revegetation plan have been made throughout section 2.05 and also <br />in the first 4 pages of section 2.04. <br />12303 Airport Way Ste 200 - Broomfield CO 80021 - Phone: 303.327.1525 - kent @gorhamenergyconsultants.com 6 <br />