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reflect appropriate and practicable reclamation targets, consistent with post-mine land use objectives, and seed mixes and revegetation practices employed. The issues addressed in the above paragraph have been the subject of discussion and correspondence among the operator, the Division, and the Colorado Division of Wildlife (DOW) for some time. The operator has indicated that they recognize the need for a comprehensive revision of the revegetation plan for the Colowyo Mine; however they have requested that the issues be addressed within a separate technical revision application, rather than within the context of PR-2. The Division concurs that, given the extent of the changes that will apply to the existing permit area as well as the PR-2 expansion areas, it is logical and appropriate that the issues be resolved through a separate permitting action. The Division is adding a stipulation to the permit regarding the reclamation plan: STIPULATION 8 NO LATER THAN 15 MARCH 2008 THE COLOWYO COAL COMPANY SHALL SUBMIT A TECHNICAL REVISION TO THE DIVISION CONTAINING A COMPREHENSIVE RECLAMATION PLAN FOR THE EAST PIT, WEST PIT, SECTION 16 PIT, SOUTH TAYLOR PIT, FACILITIES AREA, GOSSARD LOADOUT AND ALL REMAINING DISTURBANCES AT THE COLOWYO MINE. THE REVISION WILL ELIMINATE OUTDATED METHODS OF RECLAMATION THAT ARE CURRENTLY USED AT THE COLOWYO MINE. FURTHER, THE REVISION WILL ADDRESS DIVISION CONCERNS REGARDING REVEGETATION, SOILS HANDLING AND SPECIES DIVERSITY SUCCESS STANDARDS, ETC. TO MEET THE CURRENT POST- MINING LAND-USE. CONSULTATION WITH THE DIVISION, THE COLORADO DIVISION OF WILDLIFE, THE BUREAU OF LAND MANAGEMENT AND OTHER APPROPRIATE AGENCIES WILL BE NECESSARY. C. Mulching In the original permit application, Colowyo proposed that mulch was not required on slopes less than 4:1. This discussion is summarized in the original findings document and starts on page 2.05-55 of the Permit. The Division approved this proposal at that time with erosion control prior to vegetative establishment to be provided by contour plowing. Monitoring of mulched versus non-mulched azeas was required as part of Colowyo's Annual Reclamation Report. In addition, a stipulation was added to the permit requiring the use of mulching if excessive erosion does develop. Subsequent monitoring data showed that mulching was not necessary for erosion control or plant establishment. As a result of the permit renewal process in 1987, both mulching and the monitoring program were eliminated as requirements. The above-mentioned stipulation was at that time incorporated into the Permit. Proposed Decision and Findings of Compliance 4 May 2007 Permit Revision 02 Page 55