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<br />It appears on Map 19A that Colowyo is proposing to retain a terrace bench roughly <br />350 feet wide and 750 feet long between the stacktube and the crusher building <br />- location. This proposed bench does not blend into the surrounding area or <br />approximate the original wntour of the area. If Colowyo proposes to retain a <br />terrace bench it must meet the requirements of Rule 4.14.2. Under the definition <br />of approximate original contour under Section 1.04, the surface configuration <br />achieved by backfilling and grading of the mined areas should closely resemble the <br />general surface configuration of the land prior to mining and blend into an <br />complement the drainage pattern of the surrounding terrain. The proposed <br />reclamation plan does not blend in well and has steeper slopes than the surrounding <br />area. <br />Please re-evaluate the proposed post-mining configuration of the Gossard Loadout <br />area so that the slopes and post mining configuration more closely resembles the <br />approximate original contour of the area. The Division believes that the slopes can <br />be further reduced on the stacktube outslope and crusher building location to blend <br />in more with the surrounding topography of 5:1. <br />2. Regarding question 6 (previously 17), the issue of concern was that the current <br />findings document states that the success standard for cover would be based on total <br />canopy cover, whereas the permit application text indicates that herbaceous cover <br />would be the applicable parameter. Based on review on the original 1982 findings <br />document, it appears that herbaceous cover was assessed in baseline sampling, but <br />total canopy cover was established as the success standard, due to a concern that <br />cover levels based on reference area herbaceous vegetation might be insufficient for <br />erosion control. <br />Colowyo's response indicates that the success standard was changed from total cover <br />to herbaceous cover as part of the March, 1987 permit renewal process, implying that <br />the findings document should have been revised at that time. The 1987 renewal files <br />were reviewed to determine if some rational basis for revising the standard was <br />presented and accepted by the Division at that time. The Division was unable to <br />locate any documentation regarding the change in success standard. The Division <br />reviewed the 1980 baseline data in the Colowyo permit. If revegetated areas were <br />compared to the reference areas in 1980, the success standard for the mine would <br />require that total vegetative cover on revegetated areas be at least 31.8% The <br />Division is concerned about establishing a vegetative cover success standard as low <br />as 32%. The Division will postpone resolution of this question until Dan Mathews <br />of DMG inspects the Colowyo reference area this year. After looking at the <br />reference areas to see how much herbaceous and canopy cover is present, as well as <br />reviewing some revegetation data from Colowyo, the Division should be able to <br />determine whether to use total or herbaceous cover as a success standard. <br />3. Regarding question 7 (previously 19), Colowyo addressed this concern regarding <br />description of statistical testing pursuant to Rule 4.15.7(2)(c), in the second <br />paragraph on amended page 4.15-5. The proposed language is deficient for two <br />