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5 <br />significant number of acres have been reclaimed and bond released in the general New <br />Elk mine area. Nearly 30 acres have been reclaimed and revegetated at the New Elk <br />mine proper. While not sampled, there is no documented evidence through Division <br />inspection, or NECC observation, that would indicate the need for reseeding of any of <br />these acres. The nearby Golden Eagle mine was initially reclaimed and reseeded in <br />about 1997 and endured one of the worst droughts in recorded history in 2002, midway <br />through the revegetation liability period. The mine won a reclamation award fro the <br />Office of Surface Mining for the reclamation completed at this important wildlife area. <br />Any reseeding completed by the operator is reported annually by the operators, as <br />required by the Division's rules, in the Annual Reclamation Reports. Given that the <br />actual experience at these mine sites since the Division memo of 1995 is markedly <br />different than those 1995 expert opinions, NECC does not believe that a revegetation <br />failure rate of 35 -65% is warranted. It should be noted that the 20% cover standard for <br />most of the area at the West Mine at the New Elk mine is the only revegetation <br />requirement that must be demonstrated. In addition, reclamation cost estimate tasks <br />already include numerous techniques and applications including ripping, mulching, <br />fertilization, and weed control that are included for the sole purpose of maximizing the <br />success of the initial seeding efforts. NECC believes that actual experience shows that <br />when these methods are used, the initial reseeding effort can be very successful. <br />However, NECC acknowledges that isolated areas in harsh soil environments and south - <br />facing aspects can be more difficult to reestablish vegetation and considers an overall <br />revegetation failure rate of 33% to be fair and representative for cost estimating <br />purposes. <br />Disc Harrowing The commitment to disc harrow prior to broadcast or drill seeding has <br />been removed from the reclamation plan permit text discussion in permit section 2.05 <br />for a number of reasons. The currently approved reclamation plan calls for different <br />reclamation methods and practices depending on whether pre -law refuse is present or <br />not. Referring to Maps 15 and 16 of the approved PAP, areas labeled "DNR" are <br />disturbed with no refuse. Areas labeled "DR" are disturbed with an underlying variable <br />thickness of pre -law development waste or refuse. DR areas receive a thin veneer of <br />topsoil 4 -6 inches. DNR areas receive no topsoil, but are ripped prior to reseeding <br />operations, eliminating the need to disc harrow these areas prior to seeding operations. <br />Because the applied topsoil layer is very thin on DR areas, NECC believes that the mixing <br />created by the disc harrowing would be detrimental to revegetation success. For DNR <br />areas, ripping is done prior to revegetation and makes the disc harrow operation <br />redundant and unnecessary. For development waste piles and the RDA, steep outslopes <br />make the use of the disc harrow difficult if not impossible. Also, the nine inch layer of <br />topsoil approved for waste pile reclamation is loose and likely needs no further <br />manipulation prior to broadcast or drill seeding operations. <br />Miscellaneous cost estimate details As is typical, some variation in as -built structure <br />dimensions as compared to permitted dimensions occurs due to field conditions, <br />orientation and space limitations. Noted as -built variations are as follows; <br />There is one hoist house at the East Portal. The actual aerial dimension of the concrete <br />pad and hoist building is 20 feet by 40 feet. Concrete pad thickness varies considerably <br />but an average thickness of 2.5 feet is assumed for the entire pad. <br />Section 3.0 TR -68 9/29/2014 <br />