|
L •d
<br />The next issue to elaborate on is the apparent quality of the Bench 1 Substitute Subsoil and how
<br />it compares to the original Darvey -Bari subsoil that existed on the Morgan property prior to
<br />mining. The only direct comparison made between the Darvcy Bar% subsoil and the Beech 1
<br />Substitute Subsoil is in the Walsh Report on Subsoil Suitability, February 2008 (revised July
<br />2008), Attachment 2.05.4(2)(d) -1 of FR,06, sutnrnarized below.
<br />According to the Walsh Report the Beach 1 Substitute Subsoil does not meet the Percent Coarse
<br />(Rock) Fragments >3" limit of 0,1 for Land Capability Class Ile soil's (fifth column of above
<br />table). This soil physical property has a direct influence on the "Available Water Holding
<br />Capacity" of the soil, an important factor for crop production. The use of 1 ithibit D, PR-06
<br />Table 2,05.4(2)(d) -1A "Spoil and Soil Suitability Criteria (Morgan Prime Fanmiand)(Reviscd
<br />with MRCS and DRMS 2010) ". to make comparisons between the Darvey -Barr Subsoil and the
<br />Bench 1 Subsoil Substitute is misleading. All the table does is list minimum threshold levels for
<br />sleeting Prime Farmland designation, of which both the Lift B topsoil (Darvey Rata Subsoil),
<br />and East Area. (Beach 1) Subsoil Substitute do meet_ The table doei not say that the two soils are
<br />equal in nature or quality, only that they both meet the minimum threshold criteria for ?nine
<br />Farmland Soil. Mr. Dearstyne in his November 16 fetter explained the differeatebetween Prime
<br />Farmland soil csiteaia and Land Capability Classification Ile soil criteria. They are not the same;
<br />the Prime Farmland soil criteria have a much lower threshold level than the Land Capability
<br />Classification lie soil criteria.
<br />When I was asked to review PR-06, particularly the soft reclamation practices, I was under the
<br />assumption that the reclaimed soil had to only meet Prime Farmland Criteria, which it will,
<br />provided the Walsh Report is accurate and the soil handling practices outlined in P1.06 axe
<br />followed. Therefore, I did approve PR -06 as written out October 1, 2010. 'But Ms. Tamer's
<br />question is asking if the Beach 1 Substitute Subsoil is equal to in nature to the original Darvey-
<br />Barx soil. The short answer to her question is no, it is not! This is based upon two criteria for
<br />class II soils (which the Darvey/Bam soil in this map unit weie mapped and cl.a ified as). First
<br />surface rock fragments greater than 3 inches in diameter cannot exceed 0.1 percent by volume.
<br />Second, EC values in the top 20 inches cannot exceed 2 and cannot exceed 4 in the top 40
<br />inches. In addition, according to the San Miguel Soil Survey Area report under Engineering
<br />Index Tables, it shows that Barr soils have 0 pendent. rock fragments greater than 3 niches in. all
<br />horizons, and 100 percent passing the number 4 and number 10 sieves (I .e., no pent greater
<br />than tram and less than 3 inches in diameter - gravel). 1 also standby this analysis and my
<br />PLTF 001047
<br />Z89L 6
<br />aew ueloof
<br />Average Paste EC
<br />(mmhoslem)
<br />Average
<br />percent
<br />CaCo3
<br />Average Percent 1- Average
<br />Coarse (Rock)
<br />Fragments 4"
<br />20.7
<br />Percent
<br />Coarse (Rook)
<br />Fragments >3''.
<br />0
<br />Daivey-Berx
<br />Subsoil
<br />1.9
<br />17
<br />Bends 1
<br />Substitute _
<br />Subsoil
<br />3.1
<br />2
<br />5.89
<br />6:37
<br />Band
<br />Capability
<br />• Class Ile
<br />Limits
<br />_
<br />.d - in top 40 inches
<br />of soil
<br />, No
<br />Standard
<br />•
<br />35
<br />0:1
<br />L •d
<br />The next issue to elaborate on is the apparent quality of the Bench 1 Substitute Subsoil and how
<br />it compares to the original Darvey -Bari subsoil that existed on the Morgan property prior to
<br />mining. The only direct comparison made between the Darvcy Bar% subsoil and the Beech 1
<br />Substitute Subsoil is in the Walsh Report on Subsoil Suitability, February 2008 (revised July
<br />2008), Attachment 2.05.4(2)(d) -1 of FR,06, sutnrnarized below.
<br />According to the Walsh Report the Beach 1 Substitute Subsoil does not meet the Percent Coarse
<br />(Rock) Fragments >3" limit of 0,1 for Land Capability Class Ile soil's (fifth column of above
<br />table). This soil physical property has a direct influence on the "Available Water Holding
<br />Capacity" of the soil, an important factor for crop production. The use of 1 ithibit D, PR-06
<br />Table 2,05.4(2)(d) -1A "Spoil and Soil Suitability Criteria (Morgan Prime Fanmiand)(Reviscd
<br />with MRCS and DRMS 2010) ". to make comparisons between the Darvey -Barr Subsoil and the
<br />Bench 1 Subsoil Substitute is misleading. All the table does is list minimum threshold levels for
<br />sleeting Prime Farmland designation, of which both the Lift B topsoil (Darvey Rata Subsoil),
<br />and East Area. (Beach 1) Subsoil Substitute do meet_ The table doei not say that the two soils are
<br />equal in nature or quality, only that they both meet the minimum threshold criteria for ?nine
<br />Farmland Soil. Mr. Dearstyne in his November 16 fetter explained the differeatebetween Prime
<br />Farmland soil csiteaia and Land Capability Classification Ile soil criteria. They are not the same;
<br />the Prime Farmland soil criteria have a much lower threshold level than the Land Capability
<br />Classification lie soil criteria.
<br />When I was asked to review PR-06, particularly the soft reclamation practices, I was under the
<br />assumption that the reclaimed soil had to only meet Prime Farmland Criteria, which it will,
<br />provided the Walsh Report is accurate and the soil handling practices outlined in P1.06 axe
<br />followed. Therefore, I did approve PR -06 as written out October 1, 2010. 'But Ms. Tamer's
<br />question is asking if the Beach 1 Substitute Subsoil is equal to in nature to the original Darvey-
<br />Barx soil. The short answer to her question is no, it is not! This is based upon two criteria for
<br />class II soils (which the Darvey/Bam soil in this map unit weie mapped and cl.a ified as). First
<br />surface rock fragments greater than 3 inches in diameter cannot exceed 0.1 percent by volume.
<br />Second, EC values in the top 20 inches cannot exceed 2 and cannot exceed 4 in the top 40
<br />inches. In addition, according to the San Miguel Soil Survey Area report under Engineering
<br />Index Tables, it shows that Barr soils have 0 pendent. rock fragments greater than 3 niches in. all
<br />horizons, and 100 percent passing the number 4 and number 10 sieves (I .e., no pent greater
<br />than tram and less than 3 inches in diameter - gravel). 1 also standby this analysis and my
<br />PLTF 001047
<br />Z89L 6
<br />aew ueloof
<br />
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