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M <br />Page 3 of 19 <br />was Prime Farmland Soil. Mr Dearstyne spoke in great length on each parameter of <br />what was needed in a soil to be cataloged as Prime Farmland soil. In conclusion, the <br />Barx, Darvey and Nyswonger soils west of 27 Road all met the Prime Farmland <br />criteria. <br />Mr. Dearstyne spoke at great lengths his findings concerning the 1998 Order 1 Soil <br />Survey conducted by Mr. Jim Irvine of InterMountain West, Ridgeway, Colorado. First, <br />the 1998 Soil Survey was a requirement from the Division before mining started and <br />was used in all WFC Mine Permit documents since 1999. The Division had approved <br />this document in the 1999 Permit renewal application as well as all other Permit <br />reviews since. In conclusion, Mr. Dearstyne stated, Mr. Irvine did a very good job <br />classifying the soils within his scope of work but had used a miss printed value of not <br />to exceed a 7.4 PH for Prime Farmland Soil that a preliminary NRCS soils report had <br />stated. The real PH value should have been a value of 8.4. Since soil samples taken <br />from the Morgan field registered PH values higher than 7.4, Mr. Irvine stated that there <br />was no Prime Farmland within the study area. Mr. Dearstyne said he would have <br />made the same mistake if presented the same documents at that time. Western <br />Fuels, then took that soil information and formulated a plan similar to what they had <br />done east of 2700 Road, spread whatever topsoil was available (two lifts) equally <br />across all reclaimed land. Perfectly legal, providing it was not Prime Farmland. Mr. <br />Dearstyne's presentation was so convincing that it was decided then and there, that all <br />soils south west of the intersection of 2700 & BB Road, within the study area, on the <br />Morgan land, was Prime Farmland Soils. Once that was decided upon, then the <br />Regulations state that any Prime Farmland Soils must go back on the same land, in <br />other words, the same landowner gets his own Prime Farmland Soil. Salvage and <br />replacement thickness will be discussed below. <br />Since WFC had already disturbed a sizeable acreage of this now reclassified Prime <br />Farmland Soil on the Morgan land, a new plan was discussed on how to remediate the <br />affected Prime Farmland area and any future Prime Farmland Soils. The plan for the <br />affected area was soon labeled as the "Backwards Plan" and the plan for the non- <br />disturbed soil was named "Forward Plan". <br />