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b) DRMS's 2002 approval of the MR -57 permit revision application allowed the first <br />lift soil salvage depth approved in PR -05 to be reduced from 1.14 feet (13.7 inches of <br />A horizon materials), to a minimum of 1.0 foot (12 inches of mixed A/B horizon <br />materials), and for the second lift soil recovery to be changed from.salvaging 2.26 <br />feet (27.1 inches of topsoil /subsoil materials), to placement of 2.8 feet (34 inches) of <br />Bench 1 overburden/spoil material, alleged to be suitable. A description in MR -57 of <br />how this Bench 1 overburden/spoil was to be demonstrated to be suitable as a plant <br />growth medium is not apparent. <br />c) In summary, DRMS's approval of the MR -51 and MR -57 permit revision <br />applications allowed the total topsoil /subsoil salvage depth approved in PR -05 to be <br />reduced from 3.4 feet (41 inches of A + B horizon materials in two separate lifts), to <br />the salvage of a minimum of 1.0 foot (12 inches) of the Morgan's mixed A/B horizon <br />materials, placed over 2.8 feet (34 inches) of Bench 1 overburden/spoil. According <br />to the DBMS, a later version of the permit text approved by the State in November of <br />2008, confirms that the eastern portion of the Morgan's prime farmland property <br />mined before 2008, was stripped in one mixed A/B lift at an average depth of 22 <br />inches and was stockpiled; and that this A/B material was to be placed over 34 inches <br />of a Bench 1 spoil material which had been deemed to be a suitable plant growth <br />medium. <br />20. By letter dated June 9, 2010, I provided you with an interim response to your May 6, 2010, <br />request for informal review of DFD's May 5, 2010, TDN decision. I explained that, based <br />on the facts presented, a final resolution of the prime farmland soils matter could not, and <br />should not, be determined until a decision was made by DRMS on WFC's then - pending <br />permit revision application (PR -6). Consequently, I proposed and you agreed that I delay <br />my final response to your request for informal review, pending the State's final decision on <br />PR -6. You subsequently instructed me to proceed with my final response following <br />DRMS's October 1, 2010, proposed decision to approve PR -6. <br />21. On November 15 -16, 2010, OSM staff working on this appeal decision, including two <br />ecologists and a soil scientist, met with you and conducted a site visit of the area in question. <br />The purpose of this visit was to gather additional information and make on- the - ground visual <br />observations in order to facilitate an accurate analysis of your concerns. Representatives of <br />NRCS accompanied OSM staff on a portion of this site visit. <br />22. As mentioned, DRMS issued a proposed decision to approve the application for PR -6 on <br />October 1, 2010. The PR -6 application addressed land use designations, revegetation plans <br />and standards, prime farmland standards, sediment control, and post mining topography. <br />Additionally, WFC proposed changes to the topsoil salvage and replacement plans approved <br />in TR -57 for the remaining mining and reclamation operations. <br />23. You filed an objection to the permit application for PR -6 on October 21, 2010. <br />Consequently, a pre - hearing conference was held on November 3, 2010, and a formal public <br />s According to the data available, an average of 52 inches of A + B horizon materials were present on the Morgan's <br />prime farmland property prior to mining disturbance. <br />6 <br />