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Page 4 of 5 <br />topsoil suitability include; N, P, K, SAR, Electrical conductivity, Soil texture, and <br />Organic Matter. <br />NECC — The permit describes the use and testing of substitute topsoil material on pages <br />2.05 -56 and 2.05 -58. <br />DRMS — This response is adequate. <br />11. Permit page 2.05 -63 states that, "contour furrows may be employed along the steeper <br />slopes of highwall reclamation areas." Several areas on the reclaimed slopes at the <br />Lorencito Canyon Mine continue to exhibit gully formation. NECC plans to conduct <br />gully repair on these slopes in 2012. The Division considers implementation of contour <br />furrows or straw bale dikes as approved in the permit appropriate to the repair efforts. <br />Please utilize approved erosion control methods in accordance with NECC's approved <br />reclamation plan. <br />NECC — Request noted. <br />12. Reclamation success criteria required 500 stems per acre of woody species on <br />approximately 10% of the approved disturbance area. This criterion applies to the post - <br />mining land use of Rangeland, and applies to the grassland community of the Jeff <br />Canyon surface mine. The currently permitted disturbance area for the Lorencito Canyon <br />Mine is 129.3 acres. 5.9 acres will be permanent roads. 123.4 acres have been reclaimed <br />(2011 ARR). Therefore, approximately. 12 acres are required to be established shrub <br />plots, (permit page 2.05 -73) with 2 -3 shrub transplant areas established each successive <br />year of reclamation. <br />Currently, 2012, there is one fenced shrub enclosure constructed on the northwest side of <br />the reclamation area with no shrubs established. NECC needs to replant the shrub plot <br />areas in order to meet this woody plant success requirement. If NECC has established <br />other shrub plot locations, an inventory of the remaining woody stems established within <br />the plot, followed by additional transplants may be necessary for NECC to meet the <br />woody plant density criteria at final bond release. <br />NECC — Request noted. <br />13. Attached is the reclamation cost estimate for the 2012 Lorencito Permit Renewal, RN -3. <br />The Division updated the reclamation cost estimate with costs updated in the second half <br />of 2011. This updated estimate represents a new liability of $793,279.42. . This <br />estimate includes tasks identified in the permit and included a cost update only, as no <br />revisions were approved since the previous estimate was last updated with the 2010 <br />Midterm Review. This RN -3 revised cost estimate is $133,841.58 less than the current <br />bond held of $927,121.00. Please review the attached estimate and if you have any <br />questions or concerns. <br />NECC — The reclamation cost estimate is acceptable. <br />