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4. Response to proposed modifications: <br />Proposed modification 1: "preserve all existing stockpiles and soils as is, and ... no modifications to same be made <br />pending completion of the testing." WFC has no plans to alter any stockpiles, except to add topsoil to the appropriate <br />topsoil stockpiles, so this comment results in no changes to either TR -61 or PR -06. WFC has complied and will comply <br />with the DRMS request to stockpile all Lift A topsoil material to be removed after August 10, 2011 separately from the <br />existing stockpiles. <br />Proposed modification 2: "it may be necessary that DRMS staff select the specific testing sites." The testing sites are <br />slated to be randomly selected under the current proposed SAP, subject to review by a certified soil scientist who may <br />vary the sampling locations in order to ensure the technical soundness of the sampling, as described in the KeyAg SAP <br />summary. We have invited NRCS, OSM, and DRMS personnel to be present during this sampling. If this protocol is <br />subject to technically well- founded criticism, we are not aware of any but would consider it if offered. <br />Proposed modification 3: "it may be necessary that testing go to greater depth where material has been disturbed." <br />Assuming this refers to the bench one stockpile, no sampling of this stockpile is proposed or necessary. In the stockpiles <br />where sampling will be conducted under TR -61, sampling will go to the full depth of the piles as described in the KeyAg <br />summary under the heading of Stockpiled Soil Resource Evaluation beginning on page 3 of the summary. <br />Proposed modification 4: "more total samples may be required." The goal of the SAP is to adequately characterize the <br />stockpiles, which are assumed to contain well -mixed materials within each pile. The current SAP calls for going to the <br />bottom of the stockpile in many instances, and the number of sampling locations is intended to be sufficient to <br />characterize the piles. If DRMS determines that a larger number of sites, or a larger number of samples to the full depth <br />of the stockpile, is technically warranted then WFC is happy to consider expanding the plan as proposed in the SAP. <br />Proposed modification 5: "Perhaps your soils experts have other ideas as to get truly representative results from the <br />testing." Indeed they do, and the purpose of the meeting among WFC, DRMS, OSM, and NRCS that took place at WFC's <br />request on September 28, 2011 was precisely to solicit such ideas. To the extent the SAP as submitted does not <br />incorporate those ideas, WFC is happy to make appropriate changes. <br />Proposed modification 6: "I am copying OSM and NRCS in on this message in the hopes that the parties can <br />cooperatively develop a protocol that takes these concerns into account." To the extent this comment calls for <br />cooperation among the Morgan family, the agencies and WFC, this is indeed the process that is already underway, that <br />was partly completed during the September 28 meeting and that will be completed through this comment period. <br />Again, if specific input from the agencies that was made on September 28, 2011 is not included in the SAP as proposed, <br />please let us know. To the extent the Commenter has technically supportable comments to make, WFC is happy to <br />listen to them as well. DRMS can determine whether the concerns expressed in the Comment rise to this standard. <br />We do not believe that the Comment supports any justifiable modification of TR61, however that TR in its current form <br />it is simply a proposal and we are happy to listen to concerns raised by any stakeholder, as long as that concern is based <br />on technically sound analysis, whether that be the Morgan family, DRMS, OSM, or NRCS. We do not think it is <br />appropriate to suggest modifications to the SAP based on innuendo or baseless accusations. <br />In closing, we would simply ask that the Commenter and his clients stick to factual information and technically well - <br />founded comments. We do not believe the Comment contains even one well- founded argument for changing the SAP <br />as proposed. <br />Best regards, <br />Chris <br />5. Conclusion: <br />4 <br />