2014-07-22_REVISION - C1981012 - Laserfiche WebLink

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Louis Head, New Elk Coal Company Page 3 July 22, 2014 The average depth of soil to be stripped from the slopes above the refuse is given in the text as 13" The volume of soil to be stripped is thus estimated, based on the area to be stripped (in acres, ac). The volume of soil estimated to be recovered (in loose cubic yards, LCY) is constant at 2,130 LCY /ac. This value assumes a swell factor for the soil of 21.80 %, which is reasonable. The table calculates an estimate of the volume of soil that can be sent to stockpile, and keeps a running estimate of the cumulative topsoil stockpile volume, at the RDA. It shows that, under an idealized production scenario, there is a net surplus of soil from the RDA of 3,939 LCY. The table is supplemented by subsequent text and a summary Topsoil Resource Table, which together allow validation of the reclamation plan and estimation of the worst -case disturbance for bonding calculations. Although the clarity has been vastly improved, the following issues remain: i. The stockpile volumes in Table 24 are in LCY. Where values from this table are referred to elsewhere in the text (page 2.05 -36, paragraphs 4 and 5; page 2.05 -37, paragraphs 3 and 5) these units should be preserved, and any references to additional swell factors should be removed; ii. The values in the Topsoil Resource Table should be revised in the light of the above comment; iii. The calculation on page 2.05 -39 should be revised with the corrected values from the Topsoil Resource Table iv. The Division will use the final calculated volume to be imported to calculate the RCE V. —w. The responses are sufficient 14. I . Reference areas /shrubs The Division supports, in principle, the proposed changes to the shrub plan. The proposed plan meets the woody plant density requirements of the approved Post - mining Land Uses by establishing a total of 6 shrub clumps around the mine site: 2 on the RDA, 2 at the East Portal facilities area, 1 at the wash plant/pond 6, and 1 at the west end of the mine near to the site of DWDA #3. Each clump will be a fenced 100 ft by 100 ft enclosure (10,000 ft2) and will be planted with 100 live transplants, to give a planting density of 1 shrub per 100 ft2. The shrubs are proposed to be watered twice per month for the first growing season. Success is defined an absolute standard of 65 live stems per clump after 2 growing seasons. This plan is a considerable departure from the previously approved plan, which saw shrubs being planted over the whole 66 acres of disturbed land designated as Wildlife Habitat (1000 /acre for upland and 1742 /acre for riparian). Success was to have been judged against reference areas. Although the reference areas have not been sampled (and will not be retained under the proposed plan), baseline data from Exhibit 15, Appendix A gives an indication of woody plant density for different vegetative community types. The least dense of those would be Ponderosa Pine, Douglas Fir, Oak (PDO), with a stem density of 2.62 stems/M2, which equates to — 10,600 stems /acre. By contrast successfully establishing shrubs under the proposed plan would see (6* 65 =) 390 stems.