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III. OBSERVATIONS AND FINDINGS <br /> PHASE 11 <br /> The parcels described in Table 1 were reclaimed between 2016 and 2017. Topsoil was distributed on the <br /> parcels in Table 1 immediately after the disturbance had been backfilled and graded. As discussed in <br /> Section II of these Findings, there is no minimum topsoil depth requirement for the parcels in Table 1. <br /> Nevertheless, topsoil depth at 15 locations was measured by Savage and Savage Environmental, the <br /> range of depths was 11.5 inches to 36 inches, with an average depth of 18.8 inches. It was verified <br /> through visual inspection that all stockpiled topsoil had been distributed across the reclaimed area. <br /> Seeding of the parcels in Table 1 took place soon after topsoil had been spread, typically between <br /> September and November of the year in which the parcel was reclaimed. <br /> Sampling to assess vegetative cover and to support a sedimentology evaluation was completed between <br /> June 23 and June 28, 2022, by Savage and Savage Environmental, following a standard methodology. <br /> Individual pads and associated roads were considered separate reclaimed sites. The area of each site was <br /> calculated as a percentage of the total area. Sites for sampling, by representative area, were then <br /> assigned. Sample locations within each sample site were randomly determined using a 50' x 50' grid <br /> representing the site. Points for transect locations within the grid were selected using a random numbers <br /> table. Points were located in the field using compass triangulation, GPS and pacing from known <br /> landmarks. <br /> Vegetation cover was estimated by the use of the point-intercept method. An ocular point frame was <br /> used to collect two data points at 1 meter intervals along a 25 meter transect, so that each sample unit <br /> comprised 50 data points. <br /> The parcels included in the SL-16 application were sampled as a single block. According to the <br /> vegetation sampling report, 15 samples were taken,which satisfied sample adequacy. Total live <br /> vegetation cover of 73.20%was reported; a value which includes several noxious weed species:Bromus <br /> tectorum, Cheatgrass (0.93%); Cirsium vulgare, Bull Thistle (0.8%); and Convolvulus arvensis, Field <br /> bindweed(0.4%). Noxious weed cover was 2.13%in total, (relative cover of 2.91%). Non-noxious <br /> weed vegetative cover was 71.07%in total, (relative cover of 97.09%). The data show that vegetative <br /> cover exceeds the revegetation success criterion of 47.74% (that is, 90% of 53.04%). <br /> The vegetation community is progressing toward one that will support the postmining land use. The <br /> sampling data show good species diversity, dominated by perennial grasses and forbs, and a low relative <br /> cover of noxious weeds. Observations made during the SL-16 inspection(as well as regular monthly <br /> inspections) accord with the sampling data, although it is noted that control of noxious weeds should <br /> continue so as to ensure that dense patches (particularly of Cirsium vulgare,Bull Thistle; Cirsium <br /> arvense, Canada Thistle; and Cynoglossum officinale, Houndstongue) do not become established. <br /> The contribution of suspended solids to streamflow outside the permit area was evaluated for the <br /> reclaimed area and the adjacent undisturbed area, using the Revised Universal Soil Loss Equation <br /> (RUSLE): <br /> C-1980-007 Page 7 of 10 <br />