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JoEllen Turner <br />970 - 864 -7682 p.13 <br />Borth Environmental Pollution Consulting, LLC October 2, 2012 <br />spoil in the bottom of the pit, then the rockier bench one and then the nicer soils. However that <br />was clearly not what I saw during my visit. <br />Additional Response to Mr. A. DeJ'ola's Report (see also above): <br />I am surprised by the assertion by Mr. Dejoia that 80% of the Morgan property was used as <br />irrigated pasture and crop land before mining. First, the definition of pasture is: <br />"Pasture (from the Latin pastus, past participle ofpascere "to feed") is land used for grazing. <br />Pasture lands in the narrow sense are enclosed tracts offarmland, grazed by domesticated <br />livestock, such as horses, cattle, sheep or swine." The pre - mining land use documented by the <br />Morgans and others was that the property was used for irrigated alfalfa, corn and other crops. <br />To use the word pasture is wrong since there were no pasturelands before mining was initiated. <br />Also Mr. Dejoia states that the Morgan property had pinion and juniper trees which also appears <br />to be incorrect. <br />Mr. Dejoia attempted to answer 7 questions in his report as well as evaluate or criticize my <br />expert statements. The 7 questions are outlined here: <br />• Determine if the entire Morgan property was prime farmland prior to mining. <br />• Determine if the mixing of the A and B horizons impaired the soil suitability to <br />be utilized for reclamation of prime farmland <br />• Assess the quality of Milt, &rift and Mixed Topsoil for reclamation of prime <br />farmland on the Morgan Property. <br />• Assess the impacts of the alleged removal of 20,000 cubic yards of soil <br />material from the Morgan Property on reclamation potential of non -prime and <br />prime farmland. <br />• Assess the impacts of utilizing bench one material as suitable subsoil on non - <br />prime farmland reclamation. <br />• Determine if soil depth will negatively impact crop productivity at the site. <br />• Determine if proposed topography of the post mining site will inhibit irrigated <br />agriculture. <br />It is very important to note that Mr. Dejoia is an agronomist and, therefore does not have the <br />training or authority to make Prime Farmland (PF) determinations. <br />Only NRCS has the authority to make a PF mapping determination. <br />(http: / /soils.usda.gov /technical/ handbook /contentslpart622.html), Soil sampling and soil survey <br />is only a small part of a PF investigation. Soil sampling and survey are conducted to determine <br />the depth of the soils, the chemical and physical properties, etc. Once this has been done MRCS <br />will make the final decision as to whether it is prime farmland based on the surveys and other <br />facts available. <br />12(Page <br />PLTF 002486 <br />