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The VLF clay liner is laid on a prepared, non-consolidating surface, compacted, and covered <br />• with a drainage layer, a synthetic liner or two depending upon the location, and covered with <br />ore in increasing depths. Thus, the liner can be created with low hydraulic conductivity, and <br />the moisture, temperature, and low permeability of the liner will be maintained in perpetuity <br />by the engineered setting. <br />CC&V submits that it is unnecessary and technically unfeasible for DBMS to require that the <br />cover proposed for the ECOSA be required to be placed in the accordance with the <br />specification of the soil liner fill for the VLF, and respectfully requests acceptance of the cover <br />design and specification as modified by DBMS' technical consulting expert Dr. Van Zyl. <br />As noted above, plant roots penetrating the cover soils could be expected over time and would <br />increase the transpiration losses of water stored in the cover soil. This would not impact the <br />utility of the cover nor is it expected to impact plant growth. CC&V has not experienced any <br />issues with plant roots penetrating into overburden materials as having an adverse impact on <br />plant growth. A lime application cost estimate is provided as a remedial reclamation tool for <br />unanticipated reclamation challenges related to soil acidity for which CC&V does not <br />anticipate but has voluntarily agreed nevertheless to include in the proposed financial <br />warranty as an additional conservative approach. As such, CC&V does not have a specific <br />area where lime is anticipated to be applied; rather a provision for liming is available if it is <br />determined at the time of growth medium placement or revegetation to be needed or <br />recommended. <br />• I. The operator plans to transplant aspen trees in the North Cresson Mine area view shed. <br />How many acres of the reclaimed North Cresson view shed will be planted with aspen? In <br />order to complete this planting CC&V plans to extract mature aspen trees using front end <br />loaders and plant them in "pads". These pads of aspen will be planted on the re-graded <br />slopes. Include in your discussions a site preparation plan and how the aspens will be <br />planted on these sites, including recipient slope preparations and reclamation of the pad <br />removal areas. CC&V has included in the detailed financial warranty calculation, a <br />commitment to irrigate these pads for two years using a water truck and a laborer. Given <br />the difficult slopes of the area, DRMS recommends CC&V utilize the same drip irrigation <br />system used in the valley leach facility to deliver the water. CC&V already has the <br />infrastructure for such a system. Please provide a drip irrigation design as recommended <br />and adjust the warranty accordingly. <br />Response. <br />Approximately 15 acres of mature aspen tree "pads" are proposed to be transplanted as part of <br />the North Cresson Mine Area Viewshed Conservation Plan. <br />The site preparation plan was not discussed in the text, as portions of the plan will vary <br />depending upon site conditions and experience of the qualified staff conducting the <br />transplants. Experiences and procedures gained by site personnel from professional <br />• organizations that specialize in tree transplanting will be implemented as part of this plan. In <br />general, the aspen pads for the North Cresson Mine Area Viewshed Conservation Plan will be <br />from areas schedule for disturbance as part of CC&V approved mining. As such, financial <br />19