2016-08-22_REVISION - C1981014 (8)

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The approved reclamation plan for the Southfield Mine is specified in Section 2.05.4 of the Permit Application Package (PAP) for the Southfield Mine. The key portion of this section of the PAP for the Phase I areas in SL -04 states that EFCI will "establish a post -mining configuration which complies with regulatory requirements for long term stability and blends with surrounding undisturbed and reclaimed areas." PHASE II Rule 3.03.1(2)(b) states, "Up to eighty-five percent of the applicable bond amount shall be released upon the establishment of vegetation which supports the approved postmining land use and which meets the approved success standard for cover... based on statistically valid data collected during a single year of the liability period." In regard to Phase II bond release, Rule 3.03.2(3)(b) also states, "No more than sixty (60) percent of the bond shall be released so long as the lands to which the release would be applicable are contributing suspended solids to streamflow or runoff outside the permit area in excess of premining levels as determined by baseline data or in excess of levels determined on adjacent nonmined areas." With regard to Phase II bond release, the approved reclamation plan calls for the following. REQUIRED TOPSOIL REPLACEMENT DEPTH The average replacement thickness of topsoil in the mine facilities area is approved to be approximately six inches (Section 2.05.4 in the PAP). VEGETATIVE COVER SUCCESS STANDARD The vegetative cover standard in Section 2.05.4 of the PAP indicates that herbaceous cover will be considered successful when herbaceous cover on the reclaimed area is greater than or equal to 90 percent of the herbaceous cover from the reference areas. (At Southfield, multiple reference areas are used and the cover value comes from a weighted average based on acreage.) POST MINING LAND USE (IN TERMS OF HOW THE VEGETATIVE COMMUNITY WILL SUPPORT THE LAND USE Section 2.05.4 states that all existing and future disturbance within the Southfield mine and loadout areas will be reclaimed to post -mining land uses of rangeland and wildlife habitat consistent with pre -mining land use patterns. EFCI's revegetation plan is the final step in reclaiming the land to productive, self- sustaining uses as rangeland and wildlife habitat for domestic livestock and wildlife species. This plan utilizes baseline data and provides for sustainable species that are valuable to both livestock and wildlife. SUSPENDED SOLIDS ESTIMATES Sediment demonstrations for Phase II bond releases are not necessary for SL -04 areas because the road Southfield Mine C-1981-014 Page 6 of 12 August 22, 2016 SL -04