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feet is projectedfor "Block'B" irrigated pasturelands, 1.1 feet for "Block C <br />which includes both Irrigated pasturelands and dryland pasture; and <br />approximately 1 foot for "Block D" dryland pasture. Two 1ft soil replacements <br />will be used on all replacement areas a-wept. "Block D ", where single lift <br />replacement will be utilized (p. 12/13) <br />The Division has determined that, for most soil types within the New Horizon 2 <br />permit area and the .PR-O5 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 />(4.06 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. For <br />these soils, the A horizon and upper portions of the B will be salvaged in one lift, <br />with lower portions of the B and portions of the C horizon salvaged in a separate <br />lift. Two upland soil map units within the .PR-OS revision area that support native <br />rangeland are characterized by thin surface horizons. Within these units (98B <br />and 98H), A, B. and portions of the C horizons will be combined in a single 1 <br />Single lift soil replacement will be employed on dryland posture reclaimed areas <br />(Replacement Block "D", on Map 205,4-4), whereas two lift replacement will be <br />employed on irrigated pastureland and hayland (Replacement Blocks "A ", "B <br />and "C") (p 30) <br />To summarize,, the most recently updated Division Findings documcnt indicates that the <br />Division had approved, in Permit Revision 5 (P.R-5), a soil replacement plan, for the N1.4- <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 mining. <br />Salvage thickmessm for upper, lower, or mixed horizon lifts were based on physical and <br />cbermical 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", dorninated .by the deep Darvey-Barx complex map unit, and located within areas <br />managed for irrigated hayland or irrigated pastureland, had a specification for two lift <br />replacement, with a total average .replacement thickness of 3 A feet. <br />Division Adequacy Concerns Regarding Topsoil Salvage and Replacement <br />Procedures for the Nit-2, Pit-5 (19") Expansion Area <br />There apparently have beerx 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. We have the following <br />questions and concerns regarding various aspects of the plan, presented in the cuerent <br />permit application. <br />1 <br />a