2018-07-09_PERMIT FILE - C1981019A (24)

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RULE 2 PERMITS 15% slope) at the discretion of the reclamation coordinator for given opportunities that may be presented. However, in any such circumstances where the 10% slope limitation is exceeded, the "banding" technique will necessarily become a standard (mandatory) procedure to preclude excessive erosion if no other methods of erosion control are implemented. Mulching Techniques During the initial permit review process, Colowyo proposed that on slopes flatter than 4h:ly that rather than utilize a hay mulch, a stubble mulch or no mulch be used on reclaimed areas. The use of mulch on these relatively flat slopes was of no value towards reclamation at the Colowyo site. The application of mulch had become a very expensive, time consuming process which, in fact, produced additional problems on the reclaimed areas, rather than solving an assumed erosion problem that can be solved by other methods. The added flexibility of eliminating the use of any mulch greatly enhances the germination of seeds earlier in the spring given the moisture and soil temperature conditions found at the Colowyo site. Mulches tend to shade the soil, thus slowing the rise in soil temperature needed for germination of seeds. At Colowyo, soil moisture is not usually a limiting factor. Soil moisture is usually very high during the spring, due to precipitation during the winter and early spring months. The summer months are generally dry, often with little additional precipitation. By eliminating the use of mulch, the soil temperature is increased earlier in the spring, thus enabling the seeds to germinate earlier when soil moisture conditions are optimum. When the seeds germinate earlier, they are able to utilize soil moisture earlier in the growing season. This results in further root development by the plants, aiding survival through the dry summer months. Only south -facing slopes would benefit from the use of mulch under the moisture conditions at the Colowyo Mine. Without the use of a mulch, erosion control has been maintained with surface manipulation methods such as contour furrows, drainage benches and permanent drainage' channels. The initial reclamation at Colowyo that began in 1978 is indisputable evidence that the methods used at Colowyo have proven highly successful in controlling erosion on slopes as steep as 3h:ly until vegetative cover has established. Where deemed necessary by the reclamation coordinator (e.g., sagebrush steppe targeted areas, south -facing slopes, etc.), techniques such as mulching, chisel plowing, or discing on the contour will be reinstated as necessary. Irrigation No irrigation is planned for areas to be seeded. Pest and Disease Control Noxious plants, as defined in Section 1.04, will be managed in accordance with the following section — "Weed Management Plan". If insects become a problem to the point where they endanger the successful establishment of the seeded vegetation on the reclaimed area, they will also be Rule 2 Permits 2.05-36 Revision Date: 5/25/18 Revision No.: RN -07