2018-06-05_PERMIT FILE - C1981019A (6)

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RULE 2 PERMITS kt�R. P'::.'^.0"1".i`k'Y� ."'q.iCiXfi$'�`:itM,�;' k"•4w''• ' 4*,i'.'r5#r�•YsJ1�'f7•`. sed,HR:'.'D.M7'145:Xak"�'�#A'�'."% aiv'&'�>t48. -. .....`Yl� 3Y.4'ff prior to the first major snowfall event; 9)placement of thin layers of topsoil over overburden; 10)possible placement of zero topsoil; 11) possible placement of thin layers of overburden over topsoil; 12) use of specialized seed placement equipment to obtain correct planting depths; 13) use of seedbed preparation equipment and techniques to encourage sagebrush emergence; and 14) interseeding of additional grasses and/or forbs (only where necessary) following a period of 2 —3 years of growth by shrubs. All of these possible techniques/metrics are designed to diminish the competitive advantage of grasses,at least in the early stages of establishment and growth. The primary"foundation-building"element for this approach is the ability to replace variable topsoil depths and/or quality of soil materials depending on site-specific needs,the discretion of the field construction supervisor, and the capabilities(or lack thereof)of available materials and equipment. The following practices will not be promoted or practiced at Colowyo with respect to the topsoil resource: 1) Topsoil will not be "buried in place" within the footprints of existing stockpiles in order to reduce the amount of resource to be moved and placed on reclamation areas. 2) At no time will topsoil be placed without adequate metrics in place to accurately estimate volumes placed within each reclamation unit to ensure an accurate accounting of the topsoil balance. 3) Topsoil will not be placed indiscriminately within reclamation units in a manner that does not serve a specific defendable purpose regarding vegetation type establishment or location within the reclamation unit or localized watershed. In summary, application of PERA on "shrub-favorable areas" would be based on the community development contributory factors of: 1) soil quantity,quality,and replacement depth;2)aspect, slope,and landform; 3)documented and expected performance of various floral species; 4)revegetation metrics; and 5)the target post-mining land use. In this manner,reclamation and resultant developing communities will be encouraged to follow a more natural path to maturation and successional progression as opposed to more historically utilized grassland favorable approaches that should only be applied to the remaining 60% to 80% of reclaimed ground (sloping areas). However, there will likely be instances, if not an overall need,to incorporate managerial practices to encourage or protect positive recruitment to the shrub populations. Such management may include the following steps: • Use of elevated quantities of sagebrush seed within the grassland target areas, and placement of that seed in a manner to encourage sagebrush emergence. • Use of limited livestock (cattle) grazing to select against grasses and for shrubs and forbs. • Use of elk-proof fencing to preclude access into large blocks of maturing shrub populations,especially core areas. • Use of hunting pressure to reduce elk utilization of new reclamation where it can be incorporated in a safe manner given proximity to active mining. Develop special seasons in concert with CPW for management of"refuge" elk. For obvious reasons, any activity in this regard would have to be designed and approved for implementation in accordance with applicable statutes. Furthermore, approvals from appropriate agencies (CPW, MSHA, etc.) will be obtained as necessary. Rule 2 Permits 2.05-21 Revision Date: 10/3/16 Revision No.: MR-163