2019-04-29_PERMIT FILE - C1981019A (6)

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RULE 2 PERMITS 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. • Use of orchard grass (Dactylis glomerata) in key reclamation locations to encourage elk away from maturing shrub populations. It has been documented that this taxon is heavily utilized by foraging elk. • Implement procedures for micro -habitat development whereby snow catchment is encouraged and shrub heavy mixes can be applied. • Interseeding of shrubs (as necessary as a normal husbandry practice) within areas not exhibiting satisfactory establishment of shrubs, but still presenting opportunities (micro -niches) for shrubs. Such interseeding would be performed in accordance with Rule 4.15.7(5)(g), and documentation of any such efforts would be provided in the Rule 2 Permits 2.05-23 Revision Date: 5/25/18 Revision No.: RN -07