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<br />5. Soil descriptions, suitability summary information, and test results in the Volume 9 Soils <br />Appendix for the mine area and Exhibit 7 for the loadout area do not appear to confirm the <br />statement in the initial paragraph of amended page 74a, that soil resources "have high pH levels <br />which will result in poor availability of phosphorus". In contrast, the data generally show "good" <br />ratings for pH, with most samples in the neutral range, and no indications of excessive alkalinity. <br />The referenced difficulty of incorporating P fertilizer in the same paragraph, could be addressed by <br />disking or other standard tillage on drill seeded areas, and by "extensive roughening" operations <br />on steep slope locations. <br />Data generally appear to show that "A" horizon soils are suitable, with adequate fertility levels, <br />while "B" and "C" horizon materials and other potential growth materials are generally suitable for <br />plant growth media, but typically exhibit lower levels of fertility. It would appear that replaced <br />topsoil will generally consist of "A" or mixed "A" and "B" materials, and would be expected to <br />exhibit adequate fertility for native species without amendment. Surface materials associated with <br />regraded East Mine bench and loadout area locations, would likely include a mix of upper soil <br />horizons, subsoils, and underlying materials, and would likely exhibit lower levels of fertility than <br />replaced topsoils, due to dilution and inverse replacement. For the reasons indicated in the <br />amended text, application of nitrogen fertilizer at the time of initial seeding is not recommended. <br />Application of phosphorus may be warranted on non-topsoiled areas however, and due to the fact <br />that phosphorus fertilizer needs to be incorporated into the soil, it should be added, if warranted, <br />prior to seedbed preparation operations. <br />Please amend the "Fertilization Methods" narrative on page 74a, to specify soil testing (from <br />representative composite sampling of upper 12 inches of growth medium) within logical <br />reclamation parcels for all final reclamation areas that are not topsoiled. Sampling should <br />include the parameters specified in second paragraph under (2)(e)(v), on amended page 74a, <br />with the addition of testing for organic matter and texture/particle size analysis. Standard <br />analytical procedures should be specified [e.g. Saturated Paste Extract for pH, EC, and (Na, <br />Ca, Mg., for SAR calculation), AB-DTPA extract method for remaining chemical <br />parameters, hydrometer method for particle size analysis (report as % sand/silt/clay and <br />texture)] . Narrative should specify that P fertilizer would be applied prior to seedbed <br />preparation based on the results of the soil test analyses, and that areas of low nitrogen <br />fertility would be visually assessed and N fertilizer added in a subsequent growing season, if <br />vegetative growth indicates that such amendment is warranted. <br />6. Review of the reclamation plan indicates that topsoil will (or has previously been) replaced on all <br />final reclamation areas at the West Mine. Average replacement depths of 8-9 inches are listed for <br />the waste disposal area, and 24 inches for certain other locations, but no narrative, table, or map <br />that presents a comprehensive listing of average topsoil replacement thickness for each logical <br />reclamation parcel (based on salvaged volume and final reclamation acreage) could be located. <br />Please provide a narrative, table, or map that specifies average replacement thickness for <br />each logical reclamation parcel to be topsoiled. <br />7. The section heading at the top of page 59 (2.05.4(3)(a)) would appear to contain a typographical <br />error, and should be 2.05.4(2)(a). Please correct the heading. <br />2