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

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of soil texture, organic matter, and overall general fertility of soils decreases with increasing depth. Another factor is overall field capacity, moisture holding and fertility holding capacity, which generally decreases as soil texture tends toward sand and gravel, as in this instance. This can be compounded in irrigated lands by the concentration of salts at lower levels of the soil horizon, where it exists. To capture the entire solum of such soils is ill advised for purposes of reclamation and a prescription for revegetation failure on drastically disturbed lands. It has been widely understood in such circumstances, as established by over three decades of similar permits in similarly sited locations, to salvage the upper six inches of such soils and set that aside for establishment of grasses. What is commonly absent in the regulation and OMLR review is a consideration of rooting depth, which this application volunteers and discusses at some length. The application assures a proper rooting depth of two feet, which is adequate in most instances, even with a restrictive layer, for which at this location there is not. The application under Exhibit I/J offers assurances of an additional 18 inches in depth of unconsolidated material to aid in root growth development, or two feet when the replaced soil depth is considered. This depth can be assured for any discovered compacted areas by the use of rippers. Generally, compaction and unconsolidated materials are not a concern over the un- extracted segments of the site and should be more than adequate to assure unconsolidated depths beyond two feet, and sufficient to establish grasses, trees and shrubs. As the site will be returned to developed water resources, the establishment of trees and shrubs are not prescribed, only grasses. The OMLR has a history of approving shallower rooting depths for rock quarries and is essentially absent of this consideration in its regulations, reviews, and absent of any data gathering of the thousands of sites reclaimed and released over its 42 year history. While the applicant commits to a minimum replacement of six inches of soil under an environment of regulatory force; as assured by the larger Ap layer evident over South Field, depths may be greater since material placement by heavy equipment isn't exactly performed with surgical precision. Regardless, the use of the term `topsoil' has specific limitations. Even the definition under Rule 1.1(52) topsoil is described as the material at the surface of the earth which has been so modified and acted upon by physical, chemical, and biological agents that it will support rooted plants necessary to achieve reclamation goals. It is highly improbable that depths beyond 6 inches over poorly developed soil profiles meet even this intent. Varra Companies, Inc. Coulson Resource Project OMLR M- 2013 -064 8 Correspondence to Peter Hays 21 January 2014