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additional detail regarding the extensive roughening procedure(s) to be <br />employed (e.g. track-hoe gouging or contour dozer ripping specifications). <br />5. Soil descriptions, suitability summary information, and test results in the Volume <br />9 Soils Appendix for the mine area and Exhibit 7 for the loadout area do not <br />appear to confirm the statement in the initial paragraph of amended page 74a, that <br />soil resources "have high pH levels which will result in poor availability of <br />phosphorus". In contrast, the data generally show "good" ratings for pH, with <br />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 <br />be addressed by disking or other standard tillage on drill seeded areas, and by <br />"extensive roughening" operations on steep slope locations. <br />Data generally appear to show that "A" horizon soils are suitable, with adequate <br />fertility levels, while "B" and "C" horizon materials and other potential growth <br />materials are generally suitable for plant growth media, but typically exhibit lower <br />levels of fertility. It would appear that replaced topsoil will generally consist of <br />"A" or mixed "A" and "B" materials, and would be expected to exhibit adequate <br />fertility for native species without amendment. Surface materials associated with <br />regraded East Mine bench and loadouf area locations, would likely include a mix <br />of upper soil horizons, subsoils, and underlying materials, and would likely <br />exhibit lower levels of fertility than replaced topsoils, due to dilution and inverse <br />replacement. For the reasons indicated in the amended text, application of <br />nitrogen fertilizer at the time of initial seeding is not recommended. Application <br />of phosphorus may be warranted on non-topsoiled areas however, and due to the <br />fact that phosphorus fertilizer needs to be incorporated into the soil, it should be <br />added, if warranted, prior to seedbed preparation operations. <br />Please amend the "Fertilization Methods" narrative on page 74a, to specify <br />soil testing (from representative composite sampling of upper 12 inches of <br />growth medium) within logical reclamation parcels for all final reclamation <br />areas that are not topsoiled. Sampling should include the parameters <br />specified in second paragraph under (2)(e)(v), on amended page 74a, with the <br />addition of testing for organic matter and texture/particle size analysis. <br />Standard analytical procedures should be specified [e.g. Saturated Paste <br />Extract for pH, EC, and (Na, Ca, Mg., for SAR calculation), AB-DTPA <br />extract method for remaining chemical parameters, hydrometer method for <br />particle size analysis (report as % sand/silt/clay and texture)] . Narrative <br />should specify that P fertilizer would be applied prior to seedbed preparation <br />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 <br />growing season, if vegetative growth indicates that such amendment is <br />warranted. <br />3