2021-03-31_REVISION - C1982057 (3)

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the final inspection procedures of 3.03.2 have been satisfied. This shall not be before the expiration of the period specified for revegetation responsibility in 3.02.3." Rule 3.03.1(4) states: "No bond shall be fully released until all reclamation requirements of these Rules and the Act are fully met... The same rule further states, "No acreage shall be released from the permit area until all surface coal mining and reclamation operations on that acreage have been completed in accordance with the approved reclamation plan." Permit Requirements: Success Standards The Seneca IIW Mine reclamation plan calls for a minimum of four feet of suitable plant growth medium, including an average of 1.3 feet of topsoil to be placed on graded lands prior to revegetation where toxic or acid characteristics were encountered(Permit Tab 21). Otherwise,topsoil depths averaging 1.3 feet will be placed over graded spoil. The approved revegetation plan is discussed in Tab 22 of the Seneca IlW Mine's permit application package. Tab 22 describes the goals of reclamation,provides a revegetation plan and a description of how revegetation success will be demonstrated. The post mining land use approved for the site is for livestock grazing and wildlife habitat with a greater emphasis placed on livestock grazing. Attachment D of the SL7 bond release application includes a report and supporting documentation of how successful revegetation was measured. Attachment D was prepared by Cedar Creek Associates,Inc. (CCAI). SPL and CCAI largely refer to the SL7 bond release area as Bond Release Block No. 5 (BRB5). BRB5 and the applicable reference areas were sampled and tested for revegetation success in 2018 and 2019. This sampling and testing effort was conducted for two of the last four years of the liability period for BRB5 in accordance with Rule 4.15.7(5). Of the entire bond release area,only 358 acres were sampled for revegetation success as 9 acres of the SL7 bond release area consists of permanent features such as roadways. The revegetation success standards for vegetation cover and production are based on a comparison of the revegetated area monitoring results to the applicable Extended Reference Area(ERA)weighted results. Woody plant density and species diversity success is based on technical performance standards. BRB5 is located on the northern portion of the Seneca IIW mine therefore the northern ERA was sampled. Details of the revegetation success criteria can be found in Tab 22 of the permit application package. Sampling Methods Cover sampling was conducted using the point-intercept method. CCAI sampled randomly located and randomly oriented sample points within BRB5 and the ERA. Transects at each sample point were fifty meters in length and one hundred points were sampled along each transect. Both first-hit and all-hit data was collected. These methods conform to the approved sampling plan outlined in Tab 22 and are in accordance with Rule 4.15.11(1)(a)(1). Herbaceous production was sampled using one-half square meter(0.5m)circular plots within BRB-5 and the ERA. Each plot were randomly located behind the origin of the cover transect. Within each plot,all the herbaceous growth in a vertical projection was clipped and placed in labeled paper bags and grouped into lifeforms. Lichen,mosses,woody plant species and noxious weeds within the plot were not collected. Collected samples were oven dried at 105 degrees for 24 hours,then weighed. These methods conform to the approved sampling plan outlined in Tab 22 and are in accordance with Rule 4.15.11(1)(b)(1). Permit Number: C1982057 Page 5 of 15 Phase III