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Borch Environmental Pollution Consulting (BEPC) August 1, 2012 <br />Reference: U.S. Department of Agriculture, Natural Resources Conservation Service. National <br />Soil Survey Handbook, title 430 -VI. Available online at <br />http: / /soils.usda.gov /technical /handbook/. Accessed [07/31/2012]. <br />Based on my preliminary review of all the provided documents and soils data, the Morgan <br />property did constitute "Prime- Farmland Soils" pre- mining. Visual evidence on site, <br />historic documents, and interviews with the landowners confirm that the Morgan property <br />has historically had an adequate irrigation supply via the CCC Ditch. <br />List of evidence for this Statement: <br />NRCS letters (e.g., letter dated 4 of March 2010). <br />NRCS National Soils Survey Handbook <br />Much of the Morgan property was in the process of various stages of backfilling at <br />the time of my visit on July 24, 2012, and thus was not in farmable condition. Based on my <br />preliminary review of all the provided documents and materials, the Morgan property does <br />not, in its current condition, constitute "Prime- Farmland Soils ". In addition, it is difficult <br />to predict if the property will constitute prime- farmland soil after reclamation under <br />currently proposed reclamation practices. Physical and chemical analysis of piles of dirt <br />(e.g., the stockpiles of the mixed layers and the soil substitute) cannot alone be used to <br />predict if they will make a good soil. It is very important to note that a soil develops as a <br />function of many physical, biological and chemical factors (e.g., climate, slope, parent <br />material, vegetation, etc.). Thus, we cannot refer to the stockpiles as "soils" but rather <br />"dirt piles" (see definition of "soil" below). As set forth below, I have serious concerns that <br />the reclamation contemplated by WFC will not restore the soil conditions on the Morgan <br />property. <br />List of evidence for this Statement: <br />Personal conversations with Dr. Eugene F. Kelly (Prof. of Pedology in the Dept. Soil and Crop <br />Sciences at Colorado State University) and Dr. Ken Barberick (Prof. of Soil Sciences in the <br />Dept. Soil and Crop Sciences at Colorado State University). <br />This definition is from the Soil Science Glossary (Soil Science Society of America). <br />Soil - (i) The unconsolidated mineral or organic material on the immediate surface of the Earth <br />that serves as a natural medium for the growth of land plants. (ii) The unconsolidated mineral or <br />organic matter on the surface of the Earth that has been subjected to and shows effects of genetic <br />and environmental factors of: climate (including water and temperature effects), and macro- and <br />microorganisms, conditioned by relief, acting on parent material over a period of time. A <br />product -soil differs from the material from which it is derived in many physical, chemical, <br />biological, and morphological properties and characteristics. <br />This definition is from Soil Taxonomy, second edition. <br />soil - Soil is a natural body comprised of solids (minerals and organic matter), liquid, and gases <br />that occurs on the land surface, occupies space, and is characterized by one or both of the <br />following: horizons, or layers, that are distinguishable from the initial material as a result of <br />Page 2 of 13 <br />