2015-10-13_REVISION - C1981014 (18)

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Because woody plant occurrence in the loadout area is very limited, woody plant sampling data for the loadout areas will be compared with revised woody plant counts for the corresponding reference area will be compared with the revised woody plant counts for the corresponding reference area as documented in the baseline vegetation data. The revised woody plant count for the loadout area is 6.3 (2 trees and I shrub on the 0.48 acre area) stems per acre. If the woody plant density (calculated on a stems per acre basis using woody plant sampling data) for the loadout area is greater than or equal to the 90 percent confidence interval for corresponding revised woody plant density counts, revegetation will be deemed adequate relative to woody plant density. In connection with TR -39 the following revisions, found on revised Permit pages 2.04.10-5, 2.04.10-5a and 2.04.10-5b were made to the Southfield Permit which affect the determination of the revegetation success standards: Technical Revision No. 39 (TR -39) was submitted in May 2011, requesting to replace the Ponderosa Pine -Pinion -Juniper Woodland Reference Area (RA) (Plot B) with a new Proposed RA, Pinon-Juniper RA located on the northwest side of the Portals Reclaimed Area which Energy Fuels felt had more applicable slope aspects, soils and characteristics comparable to the Portals Area. However, due to landowner concerns and objections about changing locations of the RA, TR -39 was amended (October 2013) to retain RA Plot B and to combine the sample data of both RA's together, combining RA Plot B and the new Proposed Pinion -Juniper RA. As described on the approved Permit Pages 2.05.4-26 and 2.05.4-27, a weighted average approach will be used to calculate data by combining data from the RA "Plot A" for the Refuse Pile and the RA "Plot B" for the old Woodland RA adjacent to the Mine Portal Area. TR -39 herein adds the inclusion of the New Pinion -Juniper RA located at the northwest side of the mine Portal area to be combined with the weighted averaging factors. This methodology is referenced in the Bond Release Guideline, Example 3, Pages 25 - 26. Accordingly, final revegetation success criteria from the three (3) RA's will be calculated based upon the weighting value factors as outlined in Example 3 referenced above. Reference Area Weighted Average Calculations: The final weighted average reference area revegetation success standards for plant cover and forage production will be calculated based upon the surveyed areas of the three (3) respective reference areas. Refuse Pile Reference Area (Plot A), the New Portal Reference Area (Pinion -Juniper RA) and the old Mine Portal Reference Area (Plot B) are depicted on revised Map 16 and have been surveyed and the acreages calculated for each reference area. Weighting Acreage of the Vegetation Reference Areas (RA's): Factors Refuse Pile RA (Plot A): 2.50 Ac 0.5593 (2.50/4.47) Old Portal RA (Plot B): 0.29Ac. 0.0649 (0.42/4.47) New Portal RA (Pinion -Juniper RA): 1.68 Ac. 0.3758 (1.68/4.47) The weighting factors are then multiplied to the vegetation data values collected from each respective RA. Example: 22