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include areas of steeper slopes (perhaps up to 15% gradient). On these steeper slope areas, it <br />would be prudent to include the strip seeding technique as a standard procedure. <br />Please amend the pertinent narrative sections on pages 2.05-58 and 2.05-59 to <br />incorporate the strip seeding technique as standard procedure on slopes steeper than <br />10%. <br />Mulching Techniques in amended Section 2.05.4 <br />17. Narrative on page 2.05-59 notes that south facing slopes at Colowyo would likely benefit <br />from use of mulch. In the South Taylor revision area, there are extensive areas of long, <br />south facing slopes, up to 3:1 gradient, where use of mulch may be warranted. Benching, as <br />applied on previous 3:1 slopes at Colowyo is not proposed, and the seedmix does not <br />include the aggressive introduced rhizomatous grasses. Lesser gradient slopes seeded with <br />the sagebrush steppe seedmix might also benefit from use of mulch, given the lower grass <br />component utilized and anticipated longer period of time for development of perennial <br />ground cover. Given the extent of such slopes, and the significant changes in the seedmixes <br />and grading treatments as compared to earlier steep slope revegetation at Colowyo, the <br />Division believes inclusion of more specific mulching plans or mulching field trials on <br />slopes comparable to the South Taylor areas may be warranted. Comparison of <br />approaches/products such as a sterile stubble mulch (e.g. "Quickguard"), certified noxious <br />weed-free straw, and a 100% weed free wood-strand type mulch, to control (non-mulched) <br />plots, on slopes representative of the South Taylor slopes, is recommended. <br />Please give consideration to this concern and amend the pertinent sections as <br />appropriate. <br />Pest and Disease Control in amended Section 2.05.4 <br />18. There is a very brief (one sentence) reference to noxious plant control on amended page <br />2.05-60. The narrative does not provide the specificity required by Rule 4.15.1(5), with <br />respect to inclusion of a weed management plan in the permit. <br />Please provide a weed management plan that will meet the requirements of Rule <br />4.15.1(5). Please include strategies for management/control of "noxious weeds" as <br />defined in Rule 1.04(78) (include species currently listed as noxious by Moffat and Rio <br />Blanco County, as well as State "List A" and "List B" species that have been observed <br />or reported on the Colowyo permit area or adjacent areas). The plan will also need to <br />address management of other species that threaten the continued development of <br />desired vegetation (including specifically the species of annual brome present on the <br />permit area). <br />Postmining~Land Use [2.05.5 and 4.161 <br />19. Please amend the postmining land use narrative beginning on amended page 2.05-64 to <br />be consistent with changes requested in various revegetation plan sections. <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 10 <br />