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c. MCM Response #2: Due to droughty conditions, and concerns that any monitoring <br />would not be representative of normal conditions, MCM did not conduct revegetation <br />success monitoring in 2012. MCM plans to complete monitoring in 2014. <br />d. DRMS Response #2: R evised Page 2.05 -33 updates the "Vegetation Monitoring" of <br />the permit and revises the commitment to monitor revegetated areas. The revised page <br />indicates that revegetation success will typically be completed for reclaimed areas <br />during the 3rd year following final reclamation seeding and that this sampling effort will <br />use ocular estimation of cover. No discussion of herbaceous production sampling or <br />shrub density evaluation in regards to third year sampling was included in the revised <br />page. The operator should commit to sampling during the third year and remove the <br />word "typically" from the revised page, or discuss what actions would be taken if <br />sampling was not conducted during the 3rd year following reclamation seeding. Also, <br />ocular sampling is subjective and hard to quantify. The Division believes the sampling <br />plan for final revegetation success sampling should be used, however in accordance <br />with Rule 4.15.1(4) sample adequacy need not be achieved for the 3rd year sampling <br />effort. Please revise the proposed page accordingly. <br />e. MCM Response #3: Although not specifically required by the applicable regulatory <br />provisions, MCM is proposing the option of limited monitoring (ocular estimation) of <br />reclaimed areas in year 3 to assess the progress of vegetative reestablishment. If this <br />limited monitoring indicates poor vegetation reestablishment, there is the opportunity <br />for reseeding the areas(s) or completing other management practices to enhance <br />vegetative reestablishment, potentially without "restarting the clock" on the 10 -year <br />revegetation liability period. This approach is consistent with the applicable regulatory <br />provisions, and has been used successfully at other sites, therefore, MCM suggest that <br />no modification of the referenced text is necessary. Note also that as a result of the <br />2014 revegetation success sampling effort and associated research, MCM anticipates <br />preparing and submitting a revision to change the revegetation success criteria for <br />certain areas to a technical standard, consistent with the approved approach for similar <br />adjoining lands. <br />f. DRMS Response #3: This item is resolved. <br />Reclamation Cost Estimate; <br />MCM provided updates to Table 56, Map 25 and the "Mine Facilities" discussion in Section 2.05.3 of <br />the PAP to provide information to update the reclamation cost estimate for TR36 /RN6. Their response <br />to the Division's first adequacy review concerns is below. <br />a) MCM Response: Table 56, Map 25, and the "Mine Facilities" discussion in Section 2.05.3 of <br />the PAP have been reviewed, updated, and revised for consistency and to reflect the current <br />disposition and status of all major mine structures and facilities. Copies of these revised <br />materials are included with these responses. It is MCM's understanding that the Division will <br />utilize this updated information to review and revise the reclamation cost estimate, and will <br />provide the revised estimate for MCM's review. Once the updated reclamation cost estimate is <br />finalized, a copy will be inserted in Exhibit 25. If the Division incorporates the relevant <br />historical information from the current cost estimate in this update, it will replace the current <br />