45 Day Comment Period and May 9 Virtual Meeting, page-19

Reclamation, Habitat Reconstruction, Propagation, and Seeding

These measures are specific to reclamation activities that target the creation of Tiehm’s buckwheat habitat and are principally focused on growth media salvage and placement, as well as identification and development of habitat reconstruction sites. The following are measures that would be implemented during design, construction, operation, and closure of the Project that would be applicable to the creation of Tiehm’s buckwheat habitat: Concurrent reclamation would be completed for facilities (or portions of facilities) that are no longer needed for operations as soon as practicable and where suitable and appropriate Fugitive dust and other air emissions from disturbed and exposed surfaces would be controlled in accordance with NDEP regulations and other permits, as applicable. Ioneer would establish (or reestablish) stable surface topographic and hydrologic conditions both during operations and after reclamation to be compatible with the surrounding landscape. Ioneer has designed stable fill and cut slopes and would implement measures to control erosion and sedimentation and manage surface water and earthen materials to minimize water quality impacts. Surface soils suitable for Tiehm’s buckwheat would be segregated and managed as a growth media resource, if appropriate, and retained for reclamation. Ongoing soils evaluations would be used to describe and refine our understanding of Tiehm’s buckwheat growth media requirements. Key habitat correlates would be identified and used to focus habitat reconstruction efforts. These efforts would be refined as appropriate from the result of seeding and transplant studies to optimize reconstruction activities to the extent practicable. Habitat reconstruction would include: The soil profiles determined to contain the key habitat correlates for Tiehm’s buckwheat would be salvaged and stockpiled during construction for later use in reconstruction efforts. Appropriate sites to be the focus of reconstruction efforts would be identified considering topography and other characteristics that would maximize success of Tiehm’s buckwheat establishment. Direct seeding and transplantation of Tiehm’s buckwheat using the approaches developed during Ioneer’s ongoing research could be employed to establish Tiehm’s buckwheat within reclamation areas.