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

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RULE 2 PERMITS Related to this flexibility and as presented in revisions to Section 4.15, Colowyo commits to revised woody plant density success criteria for Phase III bond release for 2008 and later reclamation, that are somewhat less stringent than the original requirements, and are significantly less stringent for pre -2008 reclamation, but are ecologically defensible and appropriate. This commitment is in the interest of promoting the momentum of the bond release process and the pursuit of a "land -use" based reclamation program. Furthermore, this commitment on the part of Colowyo is based on the fact that the best reclamation science (30+ years ago), and significant financial expenditure went into implementation of the previous reclamation plan (and development of success criteria), and that recent experience and advancements in reclamation science now dictate less stringent requirements for a 10 -year bond responsibility period. In other words, the original woody plant density success criterion was developed without sufficient experience, knowledge, or empirical evidence and as such was established at too high a level over too short a time period. In effect, this will amount to the waiving of the previous standards and the adoption of the new proposed standards. Topsoil Redistribution Plan Prior to any mining -related disturbances, all available topsoil will be removed from the site to be disturbed as discussed in Section 2.05.3, and will be redistributed or stockpiled as necessary to satisfy the needs of the reclamation timetable as described herein. Final grading before topsoil placement will be conducted in a manner that minimizes erosion and provides a surface for the topsoil that minimizes slippage. If spoil compaction is a problem, the spoil will be ripped with a dozer to minimize compaction, assure stability and minimize slippage after topsoil replacement. Where possible, development of concave landforms (to encourage snow entrapment) will be developed on a case-by-case basis at the discretion of the field supervisor. Such landforms will still have positive drainage in accordance with overall permitted designs. Topsoil will then be redistributed and graded to a variable replacement depth following the general rule of thin topsoil (<6) inches on ridge tops to gradually thicker topsoil moving down the slopes to the drainage bottoms for the grazingland land use targeted areas (see representation below). Sagebrush Steppe areas will ideally receive an average of approximately 4 inches of topsoil that will likely be a more uniform application to encourage proper seeding depth and overall shrub establishment conditions (see representation below). Colowyo will track the volume of topsoil applied to each reclamation unit and report it within the Annual Reclamation Report each year. Colowyo utilizes load counts and time card coding to differentiate and accurately assign costs/volumes for all other material movement on the mine site. As such, Colowyo will utilize these tools to ensure the planned and appropriate volume of topsoil is applied to each reclamation unit. A visual representation of Colowyo's drainage -wide topsoil replacement strategy is provided below: Rule 2 Permits 2.05-25 Revision Date: 5/25/18 Revision No.: RN -07