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recovering the topsoil volumes the topsoil map was depicting. This shortage was <br />reported to the Colorado Division of Minerals and Geology inspector at fhaf time. In <br />the fall of 1995, all salvaged D708 Lift' 1 was redistributed onto the designated area. <br />6.73 acres were covered at 0.8 feet before the stockpile was depleted. The postmine <br />topsoil replacement map, Map 2.05.4-4 has been modified to reflect actual <br />conditions. <br />WFC will bring all available data to a meeting with the Division to discuss this item. <br />2) Section 2.05.4(2)(d) Topsoil Redistribution also states °lf additional topsoil material <br />is needed beyond what field observations suggest is available, material deemed <br />suitable will be tested to the above parameters as well as to fertility. D Since this <br />section also states that 83% of the total overburden is suitable for root growth and <br />since the bench 1 subsoil is 100% suitable, this material may be a solution to address <br />any defiaency, especially if enhanced with fertilizer or organics. <br />3) The Barx soil is considered prime fam~land in Morrtrose County if it meets certain <br />chemical and physical parameters as well as the availability of consistent reliable <br />irrigation. The Level Ipre-mine topsoil survey in Section 2.04.9 shows 4 samples out <br />of 17 in the 98E complex that are potentially Barx soil on the Morgan property. See <br />the attached Map 1 for these locations. As is seen from the map, the areas are not <br />contiguous, but form isolated samples generally surrounded by Darvey soil, which is <br />not prime farmland, even if irrigated. Pre-mine data on much of the Morgan property <br />does show flood irrigation. WFC is working with the NRCS to provide an updated <br />letter on the status of prime farmland soils. Jim Boyd suggests that if approximately <br />67% of a field contains a particular soil, then the whole field would be classified as <br />that soil group. Based on the enclosed Map 2.04.9-1, which shows the aerial map <br />from 1999, there are no fields on any property where the majority of the soil is Barx <br />soil. Based on this premise, there is no prime farmland in the permit area. Other Barx <br />soil samples exist to the north of BB Road and also east of 2700 Road. These sites <br />were either abandoned or do not have sufficent irrigation. <br />4) The approved permit topsoil replacement requirements are shown on Map 2.05.4- <br />4. Almost all of the irrigated areas west of 2700 Road are to receive a Lift 1 of 10 <br />inches and a Lift 2 of 12 inches for a total depth of 22 inches. WFC understands that <br />this conflicts with statements in the Division's Findings Document for Permit Revision <br />#5. WFC is meeting the total thickness requirements specified in the permit. We <br />understand that this issue must be resolved and are willing to discuss variations of <br />these requirements for certain properties. Before any additional soil can be <br />committed to on certain properties, a lesser thickness soil on other properties must <br />also be evaluated. The current status of the existing topsoil stockpiles, area of <br />stripped soil area of replaced soil, etc. is shown on the attached map called Topsoil <br />Status Map -January 2008. All topsoil redistribution procedures must be discussed at <br />a meeting with the DRMS. <br />Page 3 of 10 <br />