2014-09-02_REVISION - C1981014 - Laserfiche WebLink

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NEW LOADOUT REFERENCE AREA According to the existing Southfield Mine Permit Section 2.04.10 VEGETATION INFORMATION the original Loadout Reference Area was established in the 1980 Vegetation Sampling performed by John Keenan. The location of this site is shown on Permit Map 15, Loadout Area Soils, and is located immediately to the east of the Southfield Mine Loadout Permit Area. Previous vegetation sampling efforts performed on the Southfield Mine Loadout reclaimed areas have identified that the channel company, was sometime prior to 2007, completely disturbed by placing approximately four to six feet of fill on the original Loadout Vegetation Reference Area which is located immediately to the east of this site, while they were performing maintenance work on their channel. The purpose of this write -up is to address the similarity of the new proposed Loadout Reference Area site conditions with those found on the reclaimed portions being sampled by Energy Fuels Coal, Inc. (EFCI) which are being evaluated for final bond release. CDRMS REGULA TORY REQUIREMENTS FOR REFERENCE AREAS According to Rule 1.04.108 a "`reference area' means a land unit maintained under management approved by the Division for the purpose of measuring vegetation ground cover, productivity and plant species diversity that is produced naturally or by crop production methods. Reference areas must be representative of geology, soil, slope, and vegetation in the permit area as determined by pre- mining inventories." Rule 4.15.7(3) states: "In those areas where reference areas are to be used to determine the success of revegetation, these must be approved by the Division as a part of the permit according to the following criteria: (a) Reference areas shall be selected to be representative of each plant community, as defined in 2.04.10, present within the area to be disturbed, unless otherwise approved by the Division. (b) The permittee shall demonstrate statistically, to the satisfaction of the Division, that each proposed reference area is comparable to its equivalent area to be disturbed in terms of vegetative cover and herbaceous productivity and other applicable parameters ... " (ii) The permittee must demonstrate that management of the reference area will be under the permittee's control and, will remain under the permittee's control throughout the period of extended liability under the performance bond requirements of 3.02.3. (c) The size of the reference area(s) shall be sufficient to allow for valid comparisons with the revegetated area; (d) Reference areas shall be managed in a manner which is in accordance with the