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Ms. Terry Debin <br />Mr. Tom Japhet <br />November 24, 2010 <br />Page 6 of 9 <br />Though the reports are plagued by consistent lack of clarity as to the locations being discussed, <br />WFC assumes that the 51 -acre area referenced in the reports includes Zones 1, 2, and 3 shown on <br />the attached map, which together form the easternmost 51.7 acres of the Morgan property. See, <br />Map 2.04.5 -6 Topsoil Replacement Map, Morgan Property, attached hereto as Exhibit C . It <br />could as easily refer to Zone 4, which also contains approximately 51 acres if the pond in the <br />northeast corner is excluded. In any event, the map attached as Exhibit C is part of PR -06, and <br />was therefore both available and familiar to the NRCS at the time of their inspection. <br />In contrast to the assumptions of the November 16, 2010 reports, and as shown on Exhibit C, <br />Zones 1 and 2 comprising the easternmost 20 acres of the property are the only ones that will <br />receive Bench 1 Substitute Subsoil which will not be used in Zone 3 or Zone 4. Rather, Zone 4 <br />in its entirety will be reclaimed using the original Lift A and Lift B layers of topsoil (and original <br />underlying layers) that currently exist in that portion of the Morgan property. Zone 3 will be <br />reclaimed using the original Lift B and Mixed topsoil from the property, as shown in more detail <br />on Exhibit C. <br />In light of Exhibit C, the November 16, 2010 reports are not only inaccurate but irrelevant to PR- <br />06 because the property is already slated to be reclaimed to a higher standard than that specified <br />by Mr. Boyd. Where Mr. Boyd recommends use of 40 inches of topsoil over 14 inches of <br />substitute subsoil to a combined thickness of 54 inches over 70% of the acreage (Boyd letter <br />page 2), the actual permit revision already requires reclamation of (for Zone 4) the original Lift <br />A and Lift B topsoil with no substitute materials to an average depth of 58 inches over 100% of <br />the acreage except for a 3.19 acre pond, and (for Zone 3) the original Lift B and Mixed_togsoil <br />with no substitute materials to an average depth of 54 inches over 100% of the acreage The <br />entire remaining acreage in Zones 1 and 2 combined will also conform to Prime Farmland <br />standards (as discussed further below) but in any event comprise significantly less than the <br />acreage Mr. Boyd states was not Prime Farmland prior to mining. <br />The second error arises where the November 16 reports refer to inspection of material contained <br />in stockpiles designated as "OBI." The reports comment negatively on the suitability of this <br />material as subsoil. However, materials from this stockpile, even though they are original to the <br />Morgan property, will not be used as subsoil Rather, this material from OBI will be used in <br />Zone 4 to reclaim only the "final cut," i.e. the lowest level of soil replacement, well below the <br />layers of topsoil discussed above. Thus, references to OBI are similarly irrelevant to PR -06. <br />Finally, the reports make reference to inspection of subsoil material on "recently reclaimed" <br />land. As with all references to all locations in the report, the exact location on the 108 acre <br />property is never given so it is impossible to tell which area was the subject of this inspection. <br />However, reclamation has not been completed anywhere on the Morgan property, recently or <br />otherwise This is because the applicable Prime Farmlands reclamation practices require <br />