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Wade <br />August 8, 2011 <br />Page2 <br />1) The Bench 1 subsoil substitute material; <br />2) The mixed A and B horizon prime farmland soil materials that were salvaged <br />and stockpiled prior to February 2008; <br />3) The `lift A' soil materials salvaged and stockpiled since February 2008; and <br />4) The mixed B and C horizon (`lift B') soil materials that have been salvaged <br />and stockpiled for use in prime farmland reclamation since February 2008. <br />The Division's expectation is that the above required soil sampling and analysis will be <br />conducted under the direction and supervision of a professional soil scientist experienced in this <br />type of work. The sampling and data analysis plan must be developed in collaboration with the <br />Division, OSM, and the Colorado State Office of the USDA/Natural Resources Conservation <br />Service (NRCS). Once an agreed -upon sampling and data analysis strategy has been developed, <br />the plan must be submitted as a technical revision and approved by the Division prior to sampling <br />being conducted. The Technical Revision must be submitted no later than September 16, 2011. <br />Please be advised that none of the materials listed above, with the exception of the Bench 1 <br />overburden materials, may be redistributed on the Morgan property prior to the completion of the <br />required sampling and data analysis, and subsequent authorization by the Division. This <br />Technical Revision is required to ensure compliance with the applicable law and regulations. <br />It should be noted that the soil sampling plan may also include a more detailed characterization of <br />the properties of the remaining in situ Morgan topsoil and subsoil as it exists prior to salvaging. <br />In the interim, as related to these soil materials, the A horizon must be salvaged and stockpiled <br />separately from the B horizon soils, and the B horizon soils must likewise be kept separate from <br />any C horizon soils salvaged, until such time as additional sampling has determined that the <br />mixing of these soil horizons is not likely to be detrimental to achieving the restoration of the <br />agricultural capability of the prime farmlands disturbed. (Please note that in situ A, B and C <br />horizons are not necessarily equivalent to the "lift A" and "lift B" designations in use since 2008.) <br />In concert with the above required soil materials sampling effort, the Division, OSM, and the <br />NRCS State Office will also be evaluating the prime farmland reclamation plans, the soil <br />suitability criteria, the soil sampling plans, and the prime farmland yield standard included within <br />the permit. Based on the results of the soils sampling and data analysis technical revision, further <br />revisions to the permit may be warranted for the prime farmland reclamation plan. <br />We believe it would be helpful for WFC and your soil scientist to meet with representatives of the <br />Division, OSM, and the NRCS State Office, as the soil sampling plan is developed. This will <br />ensure that the proper data is collected using standardized analytical and sampling methods. <br />Sincerely, <br />David A. Berry <br />Director, Office of Mined Land Reclamation <br />CC: Director Pineda DRMS <br />Jeff Fugate AGO <br />Sandy Brown DRMS <br />Marcia Talvitie DRMS <br />Kenneth Walker OSM <br />Attachments <br />