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Greg Lewicki And Associates, PLLC <br />115.41 Warrington Court Phone: (303) 346 -5196 Fax (303 )-346 -6934 <br />Parker, CO USA 80138 E -Mail: info @lewicki.biz <br />October 28, 2013 <br />Dave Berry <br />Colorado Division of Reclamation, Mining, & Safety <br />1313 Sherman St, Room 215 <br />Denver, CO 80203 <br />PR 08 Prime Farmland Soils Information <br />Dave: <br />Here is some information regarding the prime farmland soils delineated in PR 08. Attached to <br />this letter is a map showing both the Intermountain Resource Inventory (IRI) soil mapping for <br />the New Horizon Mine and the Natural Resource Conservation Service (MRCS) soil mapping for <br />the same area, NRCS letters related to the discussion of prime farmland on the Morgan Property, <br />and the relevant soil surveys. <br />Prime farmland soil identification <br />• Barx soil (MRCS soil type 14 & 15) is considered prime in the Nucla area. <br />• Jim Irvine's 1998 soil survey that covers the Morgan Property within the permit <br />identified a Darvey -Bari complex (soil type 98E) <br />• Darvey soil is not identified in the San Miguel Soil Survey by NRCS. <br />• David Dearstyne described how Barx and Darvey are "similar soils "1 <br />• Darvey, if it had been identified in the San Miguel Survey would also have been <br />prime. <br />• Therefore Darvey -Barx is identified as a prime farmland soil at the New Horizon <br />Mine <br />Intermountain Resource Inventory (IRI)Soil Survey Report <br />o Jim Irvine claimed his work was an Order I survey; NRCS claims the Morgan <br />Property data is under the intensity of an Order II since complexes were used <br />instead of singular soil types. <br />■ "The Order I survey is a refinement of the "not yet published" Order III <br />soil survey that NRCS has conducted in the area "2 <br />'Natural Resource Consevation Service, Montrose, CO Office.February 11, 2009 Letter from David Dearstyne. pg. <br />2 <br />2Intermountain Resource Inventories, Inc. Order 1 Soil Survey for New Horizon Mine Western Fuels- Colorado, LLC. <br />Nucla, CO. March 1998. pg. 14 <br />