2013-02-04_REVISION - C1981008 (3)

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JoEllen Turner 970 -864 -7682 p.14 Bomb Environmental Pollution Consulting, LLC October 2, 2012 My statements about PF determinations were based on reading all of the letters and documents available for the Morgan property. In Jim Irvine's (NRCS) soil survey from 1998, the Darvey soils were listed as PF soils_ The difference between the Barx soils and the Darvey soils is very small. Specifically the Barx soil has evidence of translocated clay (Bt) in the form clay illuviation and an increase in clay of at least 3 to 6 percent from the overlying horizons. Barx is compared to Darvey in that it does not exhibit this clay increase. However, both of the soils have the same amount of clay for classification purposes (fine - loamy) and the same amount of calcium carbonate (calcic) - both soils are PF soils in the Nucla area of Colorado (See David Dearstyne's (NRCS) letter of Feb. 11, 2008 for additional details). More importantly, the Darvey /Barx soils in this map unit were classified as Capability Class II soils (see Jim Boyd [NRCS] letter of Jan. 14, 2011). The Boyd (NRCS) letter further states the following "...NRCS never made an official ruling prior to permit issuance that there were no prime farmland soils within the [entire] permit area. On the contrary, the San Miguel Soil Survey clearly indentifies Prime Farmland Soil within the permit boundary. Mr. Dejoia opines that only 20,000 yards of soil was removed from the Morgan property, and that this volume of removal is insignificant. No documentation was provided to substantiate these volumes, which are at odd with the calculations of NRCS, which estimated the figure to be approximately 200,000 cubic yards. (See letter of Jim Boyd, NRCS Resource Conservationist; January 14, 2011). The major problem that I have with Mr. Dejoia's assessment of the potential for "reclamation success" is that he is basing his evaluation on the reclamation criteria outlined by the DRMS in the WE permit boundary for both prime farmland and non -prime farmland within the Morgan property. It appears that Mr. Dejoia did not consider that the permit might have been approved based on incorrect data, Mixing of the A and B lifts is contrary to Colorado regulations for prime farmland soils. Dilution of the A horizons higher soil organic matter content can have direct impact on the crop yield, water holding capacity, aggregation, and nutrient retention. E.g., "Soil carbon (C) is also valuable because of its beneficial effects on crop productivity and soil quality. Soil C is the most important soil quality indicator because of its role in other biological, chemical, and physical processes." USDA - Long-Term Agricultural Management Effects on Soil Carbon - 2001 - SOIL QUALITY AGRONOMY TECHNICAL NOTE No. 12. In addition, since most of the Carbon in the stockpiled soils was mineralized to CO2 these soil must be reclaimed in a way that they contain the same amount of Carbon as the native soils, which is not an easy task. "Long -term experiments have shown the benefits of manure, adequate fertilization, and crop rotations on soil Carbon. However, even with manure and crop rotations, conventional cropping systems generally result in a steady decline of soil Carbon." USDA - Long -Term Agricultural Management Effects on Soil Carbon - 2001 - SOIL QUALITY AGRONOMY TECHNICAL Note No. 12.; see also, Arvidsson, J., Influence of soil texture and organic matter content on bulk density, air content, compression index and crop yield in field and laboratory compression experiments. Soil & Tillage Research 1998, 49, 159-170. Prime Farmland regulations of the State of Colorado mandate, inter alia, that total prime farmland acreage existing post mining shall not be less than existed prior to mining. See Regs. 131Page PLTF 002487