2014-05-19_GENERAL DOCUMENTS - C1981014 (2)

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K2T LLC South Central Land & Mining LLC 19 May 2014 Page 7 linl ited water in the initial years. There is now very little diversity in the reclaimed area besides rabbit brush and tridens grass which were not in the seed mix originally planted. These two invasive plants have compromised the desirable species that were planted. Of the 1800 seedlings that were planted, approximately 10% survived according to our calculations. We have been concerned about the plantings on our property since the very beginning. Since May 27, 2011, EFCI has been trying to move the original portal reference area established in 1980 so that the possibility that they might have enough grasses and diversity to pass the Division's reclamation standards through TR39. In an email from Linda Saunders, 7 /28/2011 Landowner Questions Reference Area and 2010 Reveg Results (Emailed) she states that according to your 1995 guidelines, the functionality or future use of the land by the property needs to be considered. In 2003 we filed a grazing plan with the Soil Conservation Service. Linda met twice with Rick Romano, Natural Resource and Conservation Service and evaluated the vegetation at the portal, refuse pile and pond. At that time we needed the rabbit brush and silver sagebrush knocked down and the new growth treated with a herbicide before reseeded of more beneficial plants could be done. The grasses can't compete with the taller shrubs that are not edible. According to Species: Chrysothanmus nauseosus by Tirmenstein, D. 1999, "Rubber rabbit brush is, in general, considered of little value to all classes of livestock although some subspecies receive at least light use by livestock during the winter months. Rubber rabbit brush is of little importance to larger mammals" and are not desirable for grazing. In the 2010 Revegetation Report, Kent Gorham notes that the herbaceous production was not achieved at the Vento area and that the rabbit brush population increased from 26.67% in 2006 to 53.33% in 2010. In TR 39 over our objections, the Division agreed to modify the reference area on December 3, 2013. Also we do not have a clear vision of the erosion potential on the steep sides of the 43 acre refuge pile. It seems that several of the past years' revegetation reports have noted lack of warm climate grasses but we have not seen any action taken by DMG to recommend how to remediate this situation. Response: .Many of the points raised in Item 5 will be addressed by the ongoing Revegetation Sample Study. EFCI believes that more than 10% of the seedlings survived but data from the Revegetation Sample Study will need to be reviewed. Rabbit brush is a very common plant in this area and it is prevalent in all the areas outside the boundaries of reclaimed area. The refuse area has slopes of 3:1 which are well within regulatory standards and were approved in the permit for Southfield. Item No. 6: Coal pillars. Our family planned to leave the pillars in place to help the stability of the mine workings. In 2013 when George Patterson provided the final closure map, we determined that