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VEGETATION AND SOIIS 1. Vegetation monitoring on the refuse pile will begin two (2) years after vegetation has been well established (see page 36, Exhibit 51). Typically, vegetation is well established between two and four years after initial seeding. Vegetation monitoring for the remainder of the mine will likewise begin two (2) years after vegetation has been well established. One of the primary purposes for conducting vegetation monitoring is to determine whether changes need to be made to the seed mix or other aspects of the revegetation plan. For the refuse pile, where the extended liability period has not been initiated, vegetation monitoring is well in advance of that conceived by the regulations to address potential revegetation issues. MCC is committed to evaluating aspects of the revegetation plan far in advance of permanent reclamation with the monitoring of the refuse pile vegetation. This early monitoring will allow evaluation and necessary revision or adaptation of any or all aspects of the revegetation plan. 2. The Noxious Weed Control Plan as contained in the permit complies with CDMG regulatory requirements. Compliance with CDMG guidelines is not mandatory. Rule 1.15.4 states in pertinent part, "...guidelines as adopted may he used [emphasis added] by permittees and applicants as non-binding guidance, suggestions or recommendations regarding procedures or information which is acceptable to the Division regarding compliance with the Act...", and "...An operator shaO be free m demonstrate comlafiance with the Act and Regulations ad'opled t6ereuader using procedures or informalion or an mterpreta[ion of the Act or Regu/ations dill'erent from that set forf6 in tlleguidelines [emphasis added]." 3. MCC responded to the Division's concerns regarding the issue of a possible topsoil deficit previously. This issue was contained in Stipulation No. 49. MCC adequately responded to this concern in the response to Stipulation 49. Please refer to a letter from Christine E. Johnston of December I5, 1993, paragraph 3. It should be noted for the record that baseline information regarding topsoil stripping depths is not precise. MCC committed to the salvage of all acceptable topsoil resources in the conduct of the mining operation. That commitment was fulfilled. If there are apparent discrepancies between projected topsoil depths and the actual amount of topsoil salvaged, it is because the amount of topsoil in-place to be salvaged was less than projected. The most accurate determination of the volume of topsoil available for reclamation comes from topsoil stockpile volumes surveyed by MCC and submitted to the Division. -5-