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RECEIVE: <br />Borcb Environmental Pollution Consultinst (BEPCI <br />August 1,,.,2012 <br />(cultivated crops include, but are not limited to, grain, forage, fiber, oilseed, sugar <br />beets, sugarcane, vegetables, tobacco, orchard, vineyard, and bush fruit crops) <br />adapted to the region in 7 or more years out of 10; or <br />(b) Xeric or ustic moisture regimes in which the available water capacity is <br />limited, but the area has a developed irrigation water supply that is dependable (a <br />dependable water supply is one in which enough water is available for irrigation <br />in 8 out of 10 years for the crops commonly grown) and of adequate quality; or, <br />(c) Aridic or toxric moisture regimes, and the area has a developed irrigation <br />water supply that is dependable and of adequate quality; and, <br />(ii) The soils have a temperature regime that is frigid, mesic, thermic, or hyperthernzic <br />(pergelic and cryic regimes are excluded). These are soils that, at a depth of 20 inches (50 <br />cm), have a mean annual temperature higher than 32 deg. F (0 deg. C). In addition, the <br />mean summer temperature at this depth in soils with an 0 horizon is higher than 47 deg. <br />F (8 deg. C); in soils that have no 0 horizon, the mean summer temperature is higher than <br />59 deg. F (15 deg. C); and, <br />(iii) The soils have a p11 between 43 and 8.4 in all horizons within'a depth of 40 <br />inches (1 meter) or in the root zone if the root zone is less than 40 inches deep; and, <br />(iv) The soils either have no water table or have a water table that is maintained at a <br />sufficient depth during the cropping season to allow cultivated crops common to the area <br />to be grown; and, <br />(v) The soils can be managed so that, in all horizons within a depth of 40 inches (1 <br />meter) or in the root zone if the root zone is less than 40 inches deep, during part of each <br />year the conductivity of the saturation extract is less than 4 mmhos/cm and the <br />exchangeable sodium percentage (ESP) is less than 15; and, <br />(vi) The soils are not flooded frequently during the growing season (less often than <br />once in 2 years); and, <br />(vii) The product of K ( erodibility factor) x percent slope is less than 2.0, and the <br />product of I (soils credibility) x C (climatic factor) does not exceed 60; and <br />(viii) The soils have a permeability rate of at least 0.06 inch (0.15 cm) per hour in <br />the upper 20 inches (SO cm) and the mean annual soil temperature at a depth of 20 <br />inches (50 cm) is less than 59 deg. F (15 deg. C); the permeability rate is not a limiting <br />factor if the mean annual soil temperature is 59 deg. F (15 deg. C) or higher; and, <br />(ix) Less than 10 percent of the surface layer (upper 6 inches) in these soils <br />consists of rock fragments coarser than 3 iucbes'(7.6 cm). <br />Question 2: Are the current reclamation plans for the Morgan property sufficient or are <br />alternative reclamation plans necessary to restore soil productivity? <br />To answer this question best possible, we must first define "sufficient ". In my opinion, <br />the property should be reclaimed to the same condition as existed pre - mining. That means that <br />Page 4 of 13 <br />NO.0743 08/10 /2012 /FRI 12:11AM <br />