2013-03-08_REVISION - C1981008 (2)

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Borch Environmental Pollution Consulting, LLC October 2, 2012 statistical effect of less than 1% (r = .008)would be statistically significant with a sample size of 500!" In my professional opinion we may apply the " Wilcoxon rank -sum test ": In statistics, the Mann — Whitney U test (also called the Mann — Whitney — Wilcoxon (MWW) or Wilcoxon rank -sum test) is a non - parametric statistical hypothesis test for assessing whether one of two samples of independent observations tends to have larger values than the other. It is one of the most well - known non - parametric significance tests. If we use this test to compare the substitute soils EC and pH values (NOT the MEAN VALUES) with the Barx A lift and the Barx B lift then it indicates that the substitute soil is statistically different from the Barx A lift but not the Barx B lift. However, the trustworthiness of this test is also hampered by the fact that it is based on only three measurements for the substitute soil. In addition, none of the samples were run as replicates, which is another problem with the data. In my opinion we do not have data -sets for the Bench One material on the Morgan property that are big enough in order to apply any reliable statistical test. As Johnson wrote in his 1999 paper: "...This paper describes how statistical hypothesis tests are often viewed, and then contrasts that interpretation with the correct one. I discuss the arbitrariness of P- values, conclusions that the null hypothesis is true, Dower analysis, and distinctions between statistical and biological significance. Statistical hypothesis testing, in which the null hypothesis about the properties of a population is almost always known a priori to be false, is contrasted with scientific hypothesis testing, which examines a credible null hypothesis about phenomena in nature..." Johnson, D. H., The insignificance of statistical significance testing. The Journal of Wildlife Management 1999, 63, 763 -772. [Times Cited: 452 (from Web of Science)] Comments to Reclamation Plan. With respect to my opinion about the current restoration plan I reemphasize that to the best of my knowledge the property has to be returned to the same or better condition than before mining was initiated. That means that not only does the reclaimed property need to meet the Prime Farmland Soil criteria but also the Land Capability Class Ile criteria. Based on the current reclamation plan, it has not been established that that the Land Capability Class IIe criteria will be met. In addition, if the approved reclamation plan is based on false or incorrect information submitted to the approving authorities then the reclamation plan is likely not sufficient for the Morgan property (see details below). In addition, both non -PF soil and PF soil should have been removed as a two lift operation. In fact, Permit Revision number 5 for the Morgan property states that "all soils would be segregated in a two lift operation, as Section 4.06 requires even for non -prime farmland fields. Also, during my visit I could see that WF did not seem to follow the reclamation plan with respect to placement of the different soils. Specifically, they should put the 111Page PLTF 002485