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and redistribution. Topsoil was thus not salvaged from, or returned to, these areas. These areas <br />were reclaimed with a topsoil substitute (select overburden material) in accordance with Section <br />4.06.2(4) of the Board's regulations. There is no specific replacement depth requirement for <br />this topsoil substitute material. <br />Other portions of the Moffat Area and the West Ridge Area were reclaimed with topsoil. <br />Topsoil is required to be replaced in the specified topsoiled Moffat Area and topsoiled West <br />Ridge Area to an average depth of 9 inches (permit page 4.3 -6). <br />Cover <br />Two cover standards are utilized to determine successful reclamation cover in the bond release <br />areas: the "Topsoiled Rangeland Standards" and the "Rangeland Substitute Soils Standards ". <br />Reclaimed areas having been reclaimed with topsoil (topsoiled Moffat Area and topsoiled <br />West Ridge Area) are required to be compared to the "Topsoiled Rangeland Standards" when <br />determining reclamation success. Reclaimed areas that were reclaimed with substitute topsoils <br />(non - topsoiled West Ridge Area and Moffat Area) are required to be compared to the <br />"Rangeland Substitute Soils Standards" when determining reclamation success. <br />The Topsoiled Rangeland Standards utilize reference areas to develop reclamation success <br />standards. Two reference areas, the snowberry /sage vegetation community and the oak <br />mountain shrub community, were sampled for cover and production to establish vegetation <br />bond release standards in accordance with Section 4.15.7 (the snowberry /sage vegetation <br />community represents 83% of the pre -mine disturbance and the oak mountain shrub <br />community represents 17% of the pre -mine disturbance). Results of vegetation sampling <br />conducted in 2005 indicate that the Topsoiled Rangeland Standard for cover for the Moffat <br />Area and the West Ridge Area bond release blocks is a mean herbaceous vegetation cover of <br />24.04 %. Results of the vegetation sampling conducted in 2006 indicate that the Topsoiled <br />Rangeland Standard for cover for the Moffat Area and the West Ridge Area bond release <br />blocks is a mean herbaceous vegetation cover of 24.18% <br />The Rangeland Substitute Soils Standards are utilized to generate the cover standard for the <br />non - topsoiled Moffat and non - topsoiled West Ridge areas (Section 4.15.10). Based on a pre - <br />redisturbance cover value, the Rangeland Substitute Soils Standard for cover is 47% total <br />ground cover (Appendix 2.4 -B of the DRMS Permit). As required by Rule 4.15.8(3)(a), the <br />reclaimed area is deemed successful if the revegetated area cover is not less than 90% of the <br />approved standard. Ninety percent of the approved standard of 47% equals 42.3 %. Actual <br />sampling, however, resulted in a cover value of less than 42.3 %. Sampling in 2005 <br />determined that cover would not achieve the 42.3% value. Application of Rule <br />4.15.11(2)(b), t -test demonstration, determined that a cover value standard of 40.95% is <br />considered successful for total ground cover. Only one year of sampling is required to <br />demonstrate achievement of the reclamation cover success standard for Phase II release. <br />Edna Mine Page 11 April 12, 2013 <br />Phase II. and III Bond Release <br />