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Borch Environmental Pollution Consulting, LLC October 2, 2012 <br />yield based on soil properties for disturbed prime farmland, as the data <br />was site specific. <br />Previous research by our group (Dunker et al., 1995) indicated that handling topsoil and subsoil <br />simultaneously with rear -dump trucks may be superior to using scrapers to place topsoil over <br />truck - hauled rooting media. The truck placed topsoil /root media system yielded significantly <br />higher than the topsoil replaced by scraper system and showed a 21% increase when averaged <br />over a three -year period. <br />From the Dunker 2012 abstract: <br />"States such as Illinois and Indiana require that reclamation success be <br />based on crop production of mined land. This process often can continue <br />for many years, especially for lands failing to meet production standards <br />in a specified time period. Needs have been expressed by landowners, <br />mine operators, and regulators for methods to expediate this process. A <br />soil property based model could relieve this burden and ensure the most <br />efficient process for returning the soil resource to the landowner. The <br />objective of our work was to develop a soil -based model to replace the <br />current crop yield -based system and to evaluate mined- land for <br />diagnostic purposes. Geo- referenced corn (Zea mays L.), soybean <br />[Glycine max (L.) Merr] , and wheat (Triticum aestivum L.) yield, cone <br />penetrometer test (CPT), VIS -NIR spectrophotometer, apparent electrical <br />conductivity (ECa), elevation and terrain derivatives, fertility, and other <br />site characteristic data were collected on fields at the Lewis Mine site in <br />southwestern IN, the Cedar Creek Mine site in western IL, and the Wildcat <br />Hills Mine site in southern IL. Soil -based productivity models were <br />developed using regression and multivariate techniques to assign <br />probabilities of meeting crop yield standards at the partial -field level. Our <br />research indicates that soil compaction and water availability primarily <br />influence a field's ability to meet crop yield standards across time. Model <br />validation between fields and among sites has been encouraging, thus we <br />propose modeling soil variability as a diagnostic tool to identifi; <br />problematic, f eld areas and to complement yield -based requirements." <br />My interpretation of Mr. Dunker's paper is that there is currently no validated, peer - reviewed and <br />state /federal approved model that can predict if a soil will become productive after reclamation. <br />In addition, the fact that Dunker in 2012 decided to include bulk density, organic matter, salinity, <br />elevation and terrain derivatives, fertility etc in his evaluation indicates to me that Mr. Dunker <br />does believe that these factors can be important. However, Mr. Dunker found in his studies that <br />compaction and water availability were some of the most important factors. Based on those <br />conclusions it worries me that the big rocks /fragments, high clay content, and low soil carbon in <br />the substitute soil will impact the bulk density and water holding capacity on the Morgan <br />property. David Dearstyne (NRCS) stated the same concerns in his letter (Nov. 16, 2010). <br />61 Page <br />PLTF 002480 <br />