2014-01-22_PERMIT FILE - M2013064 (10)

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Fertilizer rates can vary dramatically. Until a specific fertilizer recommendation is determined from soil testing of stockpiled soils prior to resoiling activity, a standard agricultural application of NPK can be applied based upon OMLR estimates of fertilizer costs in its proprietary software. In general, fertilization does not occur until AFTER grasses have emerged in order to minimize competition from weeds, and only to the extent indicated by soil tests. A starter fertilizer may be necessary if fertility levels are too low in the native soil, but this is not anticipated, and as a general rule of thumb, overall rates when recommended and applied will be comparatively lower for native grasses than for crops. Again, while the application does not forecast a need for fertilization or assume specific rates, it does provide for potential application, as identified under Exhibit L - Reclamation Costs. lO.As required by Rule 6.4.5(1), please state the depth of overburden to be salvaged, where the material will be stockpiled, and the depth to which overburden will replaced during reclamation. There is no overburden at this location. All extracted earth resources will be used and processed, stockpiled, sold, and transported off -site, with the exception of topsoil necessary to reclaim the affected lands. 11.As required by Rule 3.1.9(3), topsoil stockpiles shall be stored in places and configurations to minimize erosion and located in areas where disturbance by ongoing mining operation will be minimized. The Board may require immediate planting of annual and /or perennial grasses on topsoil stockpiles for the purpose of stabilization. Please depict on Exhibit C a typical topsoil stockpile location for each field and commit to seeding all stockpiles, if not replaced within 180 days with a temporary vegetative cover. Soils stockpiled and reserved for reclamation, and not otherwise disturbed by accumulation of additional soils or utilization during reclamation, will be stabilized with a vegetative cover established by utilizing the approved seed mixture. The seed mixture utilizes a hybrid cover species that will aid stability until the more native species have opportunity to express themselves. Since there is no rule or regulation specifying immediate stabilization, which is impossible, or a 180 day requirement, which is fiat, the applicant proposes to seed either at the end of the growing season or the onset of the next, once the stockpile has reached stasis. The approximate area and extent of the soil stockpile is shown within the plant and stockpile area on the revised Exhibit C -2: Extraction Plan Map, as Varra Companies, Inc. Coulson Resource Project OMLR M- 2013 -064 6 Correspondence to Peter Hays 21 January 2014