2013-02-04_REVISION - C1981008 (3)

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JoEllen Turner 970 - 864 -7682 p. 5 Burch Environmental Pollution Consulting, LLC October 2, 2012 Mr. Dunker recently published a paper (presented at the 2012 National Meeting of the American Society of Mining and Reclamation, Tupelo, MS Sustainable Reclamation June 8 -15, 2012. R.I. Barnhisel (Ed.) Published by ASMR, 3134 Montavesta Rd„ Lexington, KY 40502) that described compaction as one of the most limiting factors to successful row crop production (see excerpt below). Interestingly, some of the key soil attributes measured as a part of the "Illinois Permanent Program" which includes more than 448 long -term test plotsifields (the program focuses on yield testing after reclamation of mined soil) are % organic matter, topsoil depth, tillage depth, soil strength, bulk density, texture, and coarse fragments likely because these parameters are very important for crop yield. I have copied the following text from Mr. Dunker's 2012 paper (see citation above): "Research studies (Dunker et al., 1993) have shown that poor soil physical condition is the most limiting factor to successful row crop production on mined land. Critical to success are selection of the best available soil materials used in soil construction and a material handling method which will minimize compaction." "Segregation and replacement of horizons from the pre -mine soils is a practice that is required by law under many conditions. Early reclamation research was focused on the evaluation and characterization of selected soil materials to be used for soil horizon replacement or substitution, if the substituted soil material could be shown to be as productive as the natural soil horizon it replaced. Construction of minesoils with good quality soil materials and desirable physical properties is essential to attaining productivity levels necessary for bond release." Dunker 2012. In another Dunker paper it was stated that: "Currently, some [reclaimed soils] undergo 10 years of yield testing before a problem becomes evident, then, after further remediatton, another long period of testing is required. " Hooks, C. L.; Dunker, R. E., Soils based productivity evaluation. Coal Research Ctr., Southern Illinois Univ: Carbondale, 1998; p 98 -102. Based on the foregoing, I have serious concerns that the Morgan property will not be successfully reclaimed without first doing everything possible to optimize the soil chemical and physical properties with the goal of establishing a soil similar to the soil that was on the property before mining was initiated. Prime farmland has an acceptable level of acidity or alkalinity, an acceptable content of salt (< 4 dSlm) or sodium, few or no rocks, and are permeable to water and air. Since the substitute soil contains both large rocks and is saline (up to 5 dS/m) it is likely not to become a PF soil if reclaimed improperly (rocks need to be removed and salt needs to be leached). Even when rocks are located within the subsoil they are likely to move to the surface when the soil freezes and can cause damage to farm equipment and make it difficult to establish a good seeding bed for alfalfa. In addition, a lot of the organic carbon in the original soil has oxidized to CO due to above- ground storage. Thus, it is very important to ensure that the reclaimed soil has the same organic matter content as the original soil since organic matter influences the crop yield directly by increasing the soils water holding capacity, nutrient retention, aggregation, and microbial diversity. The Data provided by Key Ag and others shows that the soil stockpiles and the Bench One soil substitute have lower overall organic matter content than the undisturbed soils. 4 1Page PLTF 002478