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feet is projected for "Block?B"irrigated pasturelands, 1. l feet for "Block C ", <br />which includes both irrigated pasturelands and dryland pasture; and <br />approximately 1 foot for "Block D"dryland pasture. Two lift soil replacements <br />will be used on all replacement areas except "Block D ", where single lift <br />replacement will be utilized. gyp,12113} <br />• The Division has determined that, for most soil types within the ?Vew Horizon ? <br />permit area and the PR-05 revision area, lower portions of the B horizon and <br />portions of the C horizon shall be segregated and replaced as subsoil in order to <br />ensure soil productivity consistent with the approved post-minimg land use <br />(4.Q6.2(3)). Salvage of topsoil and subsoil in two separate lifts will be employed <br />for all map units occurring on irrigated pastureland and irrigated hayland. Far <br />these soils, the A horizon and upper portions of the B will be salvaged in one lift, <br />with tower portions of the B and portions of the C horizon salvaged in a separate <br />lift. Two upland soil map units within the PR-05 revision area that support native <br />rangeland are characterized by thin surface horizons. Within these units (9SB <br />and 98H}, A, B, and portions of the C horizons will be combined in a single lift. <br />Single lift soil replacement will be employed on dryland pasture reclaimed areas <br />(Replacement Block "D ", on Map Z. 05.4-4), whereas two lift replacement will be <br />employed on irrigated pastureland and hayland (Replacement Blocks "A ", "B ", <br />and ??C ?,). gyp. 30} <br />To summarize, the most recently updated Division Findings document indicates that the <br />Division had approved, in Permit Revision 5 APR-5), a soil replacement plan for the NH- <br />2, PR-5 expansion area, that involved 4 delineated "replacement blocks". Three of the <br />four blocks entailed two lift salvage and replacement, with replacement thickness within <br />each block reflective of the dominant soil map units present in the block prior to minin . <br />g <br />Salvage thicknesses for upper, lower, or mixed horizon lifts were based on physical and <br />chemical characteristics of the soil horizons as documented in the Soil Baseline Section <br />of the permit application, for individual soil map units. For example, Replacement Block <br />"A", dominated by the deep Darvey-Bari complex map unit, and located within areas <br />managed for irrigated hayland or irrigated pastureland, had a specification far two lift <br />replacement, with a total average replacement thickness of 3.4 feet. <br />Division Adequacy Concerns Regarding Topsoil Salvage and Replacement <br />Procedures for the NH-2, PR-5 ?1999? Expansion Area <br />There apparently have been some changes made to sections of the permit application <br />package subsequent to approval of the PR-5 expansion, as there are discrepancies <br />between the soil salvage and replacement plans described in the permit application <br />compared to plans described in the RN-4 Findings Document, as well as apparent <br />inconsistencies among various sections of the permit application. VVe have the following <br />questions and concerns regarding various aspects of the plan presented in the current <br />permit application. <br />5