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RULE 2 PERMITS <br />responsibility period is often insufficient for the adequate development of shrub populations unless an <br />excellent "take" is achieved at the time of seeding. In this regard, flexibility has been built into the <br />success evaluation process so that if a positive recruitment rate to the shrub population can be <br />demonstrated on Collom area revegetation, there would be no need to achieve elevated densities within a <br />modest time -frame such as the 10 -year responsibility period. <br />Colowyo makes the commitment to establish sagebrush steppe (comprised of both core and ecotonal <br />areas) on approximately 350 acres (minimum of 175 acres core) of the Collom area reclamation or as <br />otherwise agreed upon between Colowyo and CDRMS. This acreage is based on the following rationale: <br />1) identification of all Collom area disturbance post -mining acreage exhibiting slopes 10% or flatter (Map <br />46); 2) elimination of all small, isolated, or impractical areas for targeting this community; 3) <br />implementing "banding" (alternating strips of grassland versus shrubland) procedures on large units with <br />long slopes that might otherwise lead to excessive "snowmelt" erosion; and 4) assuming 50% shrub <br />establishment success (i.e. sufficient density) on the acreage that actually receives shrub conducive <br />metrics. Please refer to Map 46 for a representation of areas that are < 10% slope at Colowyo Mine <br />according to the proposed PMT surface. Also refer to Map 46 for the location of areas to be targeted for <br />either sagebrush steppe or grassland plant communitites. <br />Critical to the adoption of this approach is the need for Colowyo to be allowed to deviate from the plan <br />when opportunities for adding unplanned supplementary areas targeting sagebrush steppe establishment <br />present themselves. Based on the specific safeguads Colowyo will implement to manage sediment <br />control, Colowyo believes it is appropriate to apply shallow topsoil (approximate average of 4 inches) and <br />the sagebrush steppe mix to areas between 10% and 15% slope (as further described at length in this <br />revision) after consultation with the Division without modifying Map 46. Colowyo's Annual Reclamation <br />Report provided to the Division will provide specific details of topsoil applied and the seed mix applied to <br />each reclamation block. Interim revegetation monitoring will identify core areas that would benefit from <br />interseeding, etc. to ensure Colowyo's ability to establish and ideally exceed the sagebrush steppe acreage <br />establishment target. Interim revegetation monitoring efforts will also provide the information necessary <br />to identify the areas that will be formally designated as sagebrush steppe and grassland for Phase III Bond <br />Release data collection purposes. Map 46 identifies areas (according to compliance with the proposed <br />PMT surface) that should exhibit slopes between 0% and approximately 10% and are specifically targeted <br />to receive a shallow application of topsoil and the sagebrush steppe seed mix. Such flexibility will in no <br />way be allowed to circumvent the requirement to maintain a proper life -of -mine topsoil balance and <br />further supports the overall plan objective to improve shrub establishment and meet specified targets such <br />as at least 350 acres of sagebrush steppe establishment with at least 175 acres of core sagebrush steppe <br />establishment. This also includes the ability to take credit for up to 175 acres of ecotonal areas from <br />targeted sagebrush steppe seeded areas and grassland targeted areas (evolved) that exhibit high enough <br />shrub establishment success to qualify for Phase III bond release under the sagebrush steppe criteria. <br />Materials such as Map 46 provides CDRMS with Colowyo's general plan for demonstrating likely <br />success with the specific target listed above and is not a commitment by Coloywo to achieve sagebrush <br />steppe Phase III Bond release criteria on every acre initially seeded to sagebrush steppe. Areas receiving <br />initial sagebrush steppe establishment metrics may be released as grassland if they are later designated as <br />such through interim revegetation monitoring. Colowyo will discuss any planned deviations from the <br />reclamation plan with DRMS prior to their implementation to ensure compliance with the overall goals of <br />the reclamation program. Colowyo doesn't anticipate any changes to the reclamation plan that would <br />require formal revision unless PMT changes are requested that would require DRMS evaluation and <br />approval in addition to any appropriate updates to reclamation plan materials. <br />Related to this flexibility and as presented in Section 4.15, Colowyo commits to woody plant density <br />success criteria (among several others) for Phase III bond release that are ecologically defensible and <br />appropriate. This commitment is in the interest of promoting the momentum of the bond release process <br />Collom — Rule 2, Page 92 Revision Date: 11/16/16 <br />Revision No.: MR -166 <br />