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Addressee Name <br />Date <br />Page 2 <br />6. In Section 2.05.5 Postmining Land Use, page 2.05 -70, it states that the postmining <br />topography and land use are illustrated in Maps 2.05 -M6 through 2.05 -M8. Maps 2.05 - <br />M6 and 2.05 -M7 show the post mine topography with cross - sections and Map 2.05 -M8 is <br />no longer in the permit. There is no map throughout the permit showing the post- mining <br />land use for the Elk Creek Mine. Please submit a map showing the post mining land uses <br />that is consistent with the written descriptions on page 2.05 -70 and with the revegetation <br />plan. <br />7. Some areas are designated as wildlife habitat and recreational use for the post mining <br />land use. These designated land uses require the establishment of woody plant species <br />according to Rule 4.15.8(7). In Exhibit 2.05 -E6 — Revegetation Plan, a standard for <br />cover, diversity and productivity are described but there is not a standard for woody plant <br />density. Please submit a revegetation standard for woody plant density or a letter from <br />the surface land owner(s) requesting that the woody plant standard be waived. <br />Rule 2.05.4 <br />8. The reference area that will be used to determine revegetation success for bond release is <br />not well defined in the permit. The linear quantitative sample area shown on Drawing <br />2.04 -M8 extends from Sanborn Creek, through the main Elk Creek facilities area, <br />through the Bear Creek Canyon and ends in the Hubbard Creek Canyon. The sample <br />area is about 5 miles long, spans three different vegetation types and is not clearly <br />delineated. The features of this sample area make it unlikely that it could be accurately <br />located and produce repeatable results adequate for revegetation standards. Also, since <br />this sample area was established, the mine has expanded to include additional vegetation <br />types that are not represented in the sample area. The Division does not believe the <br />existing reference area represents the areas that have been disturbed. Please re- evaluate <br />the sample /reference area in accordance with Rule 4.15.7 and 4.15.8 and either <br />demonstrate how the reference area will be sampled and compared to the reclamation as <br />the revegetation success standard or develop a revised reference area and demonstration <br />to serve as the revegetation success standard. <br />9. The Elk Creek main facilities area is located in the Elk Creek Canyon, which is <br />designated as a riparian area on Drawing 2.04 -M8. There has been a significant amount <br />of disturbance to the riparian area but the permit does not address the special needs this or <br />other riparian areas will require for reclamation. Please submit a plan to reclaim the <br />riparian areas. Some of the topics that need to be covered (but not limited to) in the <br />discussion are: baseline vegetation survey, sediment control during backfill and grading <br />and all the bullet points in Rule 2.05.4(3). <br />Exhibits and Drawings <br />1. Please update all permit drawings /neaps to reflect the latest permit boundary changes of <br />PR -6 and PR -7. <br />2. Table 4 in Exhibit 2.04 -E6 is illegible. Please submit a legible version of table 4. <br />