2021-03-25_GENERAL DOCUMENTS - C1982057

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Success of species diversity is measured utilizing four tests as described in Tab 22 of the permit (Revegetation Plan),with success demonstrated when mandatory test A and two of the remaining three alternative tests(B, C or D), are passed. The tests are described as follows: o no single species exceeding 60%relative cover(mandatory test A) o species density values along with cover sampling per 100 square meters (sq m), are based on a weighted average and compared to the reference area derived standard (alternative test B). Success is demonstrated when the reclaimed area mean exceeds the 75 % standard of the distribution of species. o this test(alternative test C), establishes a relationship between the distribution of species and the references areas. If the index of similarity between the species density of the reclaimed area and the reference areas exceeds 63%,the test is passed. o Alternative test D is passed when the cumulative number of native species exceeds the average number of native species per 100 sq in,in the weighted average of reference area sampling. III. OBSERVATIONS AND FINDINGS The evaluation of this bond release application(SL6),included the bond release inspection,a review of the permit requirements and regulatory criteria,and review of past inspection reports,annual reclamation and hydrology reports. During the Phase II bond release inspection,participants walked through all parcels requested for bond release making visual assessments of compliance with the requirements as described above in Section II of this document. The 21 July 2020 inspection report details the findings from the inspection. A summary of the observations is discussed below. Several maintenance items were identified during the inspection concerning fencing and netting to be removed,a clogged culvert and a significant rill. These items were addressed by SPL and at the next DRMS inspection of the site were found to be adequately addressed. Ponds and stock ponds were in good repair and have received permanent designation from the Division of Water Resources. The requested release areas report surface runoff to sediment ponds#006,009,015,016 and 017. Constructed drainages observed where found well armored and stable with established vegetation on banks and grasses taking hold in the channel. The water quality monitoring plan referenced in Tab 15 and associated appendices of the permit document has undergone several updates over the years with the most recent update associated with permitting action TR82 in 2016. Several reductions in monitoring were granted as a result of TR82. Additionally, several parameters were suspended in 2010 as a result of TR69. The suspended parameters will be analyzed one year prior to final bond release. Phase H Reclamation parcels blended into the surrounding landscape and slopes appeared consistent with the surrounding topography. Highwalls had been eliminated. All parcels requested for Phase II release had previously been Phase I released. SPL documented topsoil depth replacement for parcels within BRB3 in the SL5 Phase II bond release application that was approved in 2014. Post mining land use comprise livestock grazing and wildlife habitat. Gradual livestock grazing was initiated in 2007 utilizing the pastures for approximately 15 days each. Grazing continues and has slowly spread to encompass the majority of the reclaimed lands as granted by landowners. Duration of grazing has increased to between 29 to 51 days per year. Wildlife frequents the site and wildlife monitoring conducted from 1994 through 2010 and through 2007 included large game,upland birds,raptors and predators. DRMS inspections routinely note the presence of big game,upland birds and raptors. Annual reclamation reports submitted to Permit Number C1982057 Prepared by: R.Reilley MS,GISP SL6 Phase II and III Page 8 of 16