2021-03-31_REVISION - C1982057 (3)

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For Alternative Test C, a similarity index test was conducted to compare the BRB5 to the ERA life form species density values. CCAI noted the performance standard for this test is 90%of 70% (63%),however in accordance with Tab 22,page 12 the performance standard should be 90%of 75% (67.5%). The similarity index was 86% and 87%in 2018 and 2019 respectively which exceeded the approved success standard of 67.5%. Alternative Test C was passed for both 2018 and 2019. For Alternative Test D,the total number of native species encountered at an adequate number of samples within BRB5 (based on allowable all-hit herbaceous cover and species density),was compared to the area weighted native species density standard(based on the extended reference areas). In 2018 the total number of native species encountered in the first sixteen 100m2 samples was 56. In 2018 the total number of native species encountered in the first fourteen 100m2 samples was 56. The 2018 area weighted native species density standard was 26.7 species per 100 m2. In 2019 the total number of native species encountered in the first fourteen 100m2 samples was 62. In 2019 the total number of native species encountered in the first seven 100m2 samples was 44. The 2019 area weighted native species density standard was 25.2 species per 100 m2. Alternative Test D is passed for the 2018 and 2019 data. In summary, Mandatory Test A was passed as were Alternative Tests B, C and D. Thus,the species diversity test as a whole is passed for the 2018 and 2019 BRB-5 and revegetation success for species diversity for Phase III is demonstrated. Conclusion The applicable revegetation success standards for BRB5 have been met. Based on this finding,the applicant has successfully established diverse vegetation that will be conducive to the post mine land use of livestock grazing and wildlife habitat. According to SPL, livestock grazing has been conducted on the mine's reclaimed lands since 2007 and stocking rates have been developed using ongoing revegetation monitoring data. SPL reports on grazing practices occurring at the site in the annual reclamation reports. Also,wildlife species have been observed by DRMS staff utilizing the reclaimed area. Given the findings in this document and the documented use of the reclaimed area for livestock grazing and wildlife, it appears the post mine land use has been achieved. Map I below illustrates the Phase III bond release areas associated with SL6 (proposed 25 March 2021), and SL7. Permit Number: C1982057 Page 12 of 15 Phase III