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Borch Environmental Pollution Consulting (BEPC) August 1, 2012 <br />the entire property should have been mined by removing the topsoil via a two lift approach <br />separating the A -lift from the B -lift. After mining, the exact same amount (soil layer depth) of <br />soil in form of the A and B lifts should have been put back in its original place. If this approach <br />had been followed then I would not have any problems with the reclamation strategy. This <br />reclamation strategy was used on some of the neighboring properties with success. <br />Review of the records, interviews, and my inspection revealed that portions of the Morgan <br />Property were stripped of top soil in a manner that did not segregate the A -lift and B -lift <br />horizions. On July 24, 2012 several piles consisting of mixed soil were visible on the property. <br />The Morgans report that portions of their top soil were shifted by WFC and applied to <br />neighboring properties to the east, resulting in a replacement soil deficit. The State of Colorado <br />apparently recognized that a reclamation approach involving replacement of all soil native to the <br />Morgan property would be impossible, and thus that a new soil needed to be created to meet <br />reclamation criteria some of which I will mention here. <br />1. The reclaimed soil needs to meet the minimum criteria for a Land Capability Class Ile <br />soil as defined by NRCS (Land Capability Classification (622.02)) and in the Agriculture <br />Handbook No. 210 (Exhibit 622 -2) after restoration. Land capability classification is a <br />system of grouping soils primarily on the basis of their capability to produce common <br />cultivated crops and pasture plants without deteriorating over a long period of time. Soil and <br />climatic limitations in relation to the use, management, and productivity of soils are the bases <br />for differentiating capability classes. Classes are based on both degree and number of <br />limitations affecting kind of use, risks of soil damage if mismanaged, needs for soil <br />management, and risks of crop failure. Capability groupings are based on specific <br />information when available information about the responses of the individual kinds of soil to <br />management and the combined effect of climate and soil on the crops grown. It comes from <br />research findings, field trials, and experiences of farmers and other agricultural workers. <br />Where information on response of soils to management is lacking, the estimates of yields and <br />the grouping of soils into capability units, subclasses, and classes are based on an evaluation <br />of combinations of the following: <br />A. Ability of the soil to give plant response to use and management as evidenced by <br />organic matter content, ease of maintaining a supply of plant nutrients, percentage base <br />saturation, cation - exchange capacity, kind of clay mineral, kind of parent material, <br />available water holding capacity, response to added plant nutrients, or other soil <br />characteristics and qualities. <br />B. Texture and structure of the soil to the depth that influences the environment of <br />roots and the movement of air and water. <br />C. Susceptibility to erosion as influenced by kind of soil (and slope) and the effect of <br />erosion on use and management. <br />Page 5 of 13 <br />