2013-02-04_REVISION - C1981008 (3)

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JoEllen Turner Borth Environmental Pollution consulting, LW October 2, 2012 8.1 Alfalfa Rooting Mr. Dejoia does not explain his conclusion indicating that the "six feet of rooting media will provide adequate water holding capacity and nutrient retention to enable the reclamation process to produce equal to or better productivity than the undisturbed prime farmland soils," As noted above it seems unlikely that, a soil that has higher salinity, less soil organic matter, more clay, and more rocks will provide a growth media which is comparable to that existing in the =tuned soil 8.2 Coarse Fragments I take issue with Mr. Dejoia's statement that rock fragments are only critical in the first 6 inches of the soil. Farmers routinely plow or rip to depths of 24 inches or more. In that event course fragments will be forced to the surface. Based on these facts, any rocks should be below two feet to prevent direct damage. When I visited the Morgan property I witnessed many rocks the size of an American football and bigger. In fact, David Dearstyne (NRCS) reported in his letter (Nov. 16, 2010) that he observed boulder sized rocks ( >24 inches). David Dearstyne also reported the presence of surface fragments in the reclaimed soil >3 inches in the topsoil. David Dearstyne also states that the high rock content in the stockpiled OBI material would likely impact the water holding capacity in a way that it would not meet the requirements for a prime farmland soil. The Morgan family reports that their soils were basically rock - free before mining. It follows that to restore equivalent productivity the soil must be substantially rock - free after the reclamation. In the absence of rock removal rocks from the subsurface will also move toward the surface as a function of time due to settling during irrigation and due to freezing of the soils in the winter, In addition to impacting soil quality rocks can also damage the farm equipment. It can also be time consuming for the farmer to have to pick stones every spring. The most important argument for ensuring that all rocks are removed from the soil is the fact that the soil can not be classified as a capability class II if the rock content is higher than 0.1% (average percent coarse (rock) fragments >3 "). Currently the Bench l substitute subsoil contains 6,37% and the undisturbed soil contains 0% (see evidence above). 9.1 Soil Removal Mr. Dejoia states that it was brought to his attention that 20,000 cubic yards of soil material may have been removed from the Morgan property for reclamation purposes on adjoining properties. His conclusion that this removal is entirely immaterial to final reclamation rests on the assertion that the removal was no more than 20,000 yards. Information from the Morgans and NRCS suggests that this conclusion may be off by a factor of ten, resulting in a topsoil loss of 12 inches, not 1.2 inches. 92 Post Mining Contours 1) By law, the grading of the property needs to be similar to the undisturbed soil. 970 - 864 -7682 p.20 191 Page PLTF 002493