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a. MCM Response: The specific Permit text discussion for the Noxious Weed Management Plan has <br />been reviewed and revised, as appropriate to address the CDRMS's expressed concerns. MCM <br />completes an annual noxious weed assessment, and then ties weed control activities during the year <br />to the results of that assessment. Spraying typically takes place during spring and fall, targeting <br />different weed species. Weed mapping has been included on the Reclamation and Building <br />Demolition Map for convenience, and so that all relevant maintenance and reclamation information <br />is provided in a consistent, concise format. MCM will work with the CDRMS to either modify this <br />map to address the CDRMS's concerns or will create a separate map. Copies of the revised Permit <br />discussion accompany these responses for replacement in the PAP. <br />b. DRMS Response: MCM added Houndstongue to the list of species to be treated in the permit. <br />The Division reviewed the 2013 Annual Reclamation Report submitted by MCM and it appears <br />weed species and control methods are discussed in the narrative of the report. The Reclamation <br />and Building Demolition Map submitted with the report delineates areas where specific herbicides <br />were used but does not indicate where specific species are encountered. Revised page 5.05 -32.1 <br />indicates the MCM maintains a working weed program map and records both observed weed <br />occurrences by weed species, location, and extent of infestations; and treatment activities. Since <br />this information exists, it should be added to the Reclamation and Building Demolition Map <br />submitted in the Annual Reclamation Report. <br />c. MCM Response #2: MCM documents weed control activities in both the text and on a map in the <br />Annual Reclamation Report. Generally, the areas delineated may include multiple weed species, <br />therefore specific locations are not delineated for individual species. MCM typically sprays in the <br />spring for whitetop, houndstongue, knapweed, and toadflax (if present), and in the fall for thistle <br />and any of the other species which remain after the spring weed control efforts. The exception to <br />this approach is tamarisk, which only occurs in certain areas and requires a separate, focused <br />control effort. When tamarisk control activities occur, they are delineated separately in the ARR. <br />d. DRMS Response #2: This item is considered resolved. <br />22. Permit page 2.05 -32c states that MCM will perform revegetation monitoring in the third year following <br />seeding. Several areas were reclaimed during the 2008 field season, making 2011 the third growing <br />season. MCM is reminded that revegetation monitoring is required for these reclaimed areas this year. <br />Please include the vegetation monitoring report with the 2011 Annual Reclamation Report. <br />a. MCM Response: MCM is completing the required revegetation success monitoring in <br />conjunction with similar work for the nearby Seneca II and Yoast Mines. The resulting monitoring <br />information will be included with the 2011 Annual Reclamation Report. <br />b. DRMS Response: It does not appear MCM submitted the vegetation monitoring data with the <br />2011 Annual Reclamation Report. However monitoring was conducted in 2011 on 11.5 acres <br />reclaimed in 2008 and submitted with the SL -3 bond release application. According to the 2013 <br />Annual Reclamation Report, final reclamation was completed on 17.1 acres encompassing the No. <br />9 Portal Area and adjacent Refuse Disposal Area in May of 2009. Given the commitment <br />discussed above, revegetation monitoring should have been conducted on these areas in 2012. <br />Please indicate if the 2012 monitoring was conducted? <br />c. MCM Response #2: Due to droughty conditions, and concerns that any monitoring would not be <br />representative of normal conditions, MCM did not conduct revegetation success monitoring in <br />2012. MCM plans to complete monitoring in 2014. <br />d. DRMS Response #2: Revised Page 2.05 -33 updates the "Vegetation Monitoring" of the permit <br />and revises the commitment to monitor revegetated areas. The revised page indicates that <br />revegetation success will typically be completed for reclaimed areas during the 3 `a year following <br />