2015-02-18_REPORT - C1981014 (3)

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2014 Annual Reclamation Report Southfield Mine obtained from the monitoring is included in the Revegetation Monitoring Report for Reclaimed Areas in the section titled "Loadout Reclamation". IME, Inc. also sampled the Loadout during 2010 and again in 2013 for Year 9 and 2014 for Year 10 vegetation monitoring requirements. The cumulative results of the 2013 and 2014 vegetation monitoring reports are not yet completed. As with the mine area stated in the forgoing section, 2014 monsoon rains promoted vigorous vegetation growth at the loadout site as well. Interim Revegetation Evaluation EFCI has revegetated a cumulative total of approximately 82.6 acres at the Mine Site and Loadout areas as shown on the attached Annual Reclamation Report form. Maps accompanying this report show all revegetated areas, with the exception of approximately 1.5 acres of minor road segments revegetated in 2003 at the North Well (a.k.a. MW -NW) and the former Corley Mine Well areas. The previously revegetated areas are shown on Map 1, Mine Site Reclamation; Map 2, Ancillary Facility Areas Reclamation and Map 3, Loadout Area Reclamation. As previously stated, during 2006, Mr. Kent Crofts of I.M.E., Inc., did the interim revegetation sampling and reporting at the mine site, the refuse pile area and at the Loadout site. Map 1 shows areas of the contemporaneous reclamation plots listing progressive dates of seeding and the approximate acreage of each plot. According to the conclusion of the I.M.E. report and as had previously been recommended by the Division, 15 cover transects, 30 production transect and 30 shrub density transects were sampled on each reclaimed site. Comparisons of the various revegetation data required are well detailed in IME's 2006 Monitoring Report. It is IME's opinion that based on their 2006 interim monitoring with respect to woody plant density for the mine portal area and the warm season species diversity, the existing Permit Revegetation Success Standards should be revised due to inconsistency of the original Reference areas for comparing revegetation success. In response to the above concern, EFCI submitted Technical Revision No.39 (TR -39) requesting approval to relocate the respective Vegetation Reference Area to an adjacent area on the north side of the mine portal area that offers more compatible aspects with the mine portal area. Following review of the revision request by the Division and acknowledging concerns of respective landowners, it was agreed to combine both the original reference area and the proposed reference area so as to include more aspects of the reference areas for better comparison of the reclaimed portals area. Accordingly, TR -39 was approved in 2013. Revegetation Monitoring & Sampling EFCI was scheduled to monitor and collect samples of the vegetation during 2012 which is Year 9 of the Ten Year Reclamation Liability Period. However, given the drought conditions experienced during the previous and current year as stated above, EFCI requested approval from 7