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has observed locations where topographic irregularities on otherwise relatively featureless <br />terrain at Colowyo have resulted in the effect described, and believe the creation of <br />topographic variation, particularly on the relatively flat, exposed bench-like ridges, would <br />likely be quite beneficial. <br />Please provide additional detail regarding the scale and spacing of the features <br />envisioned, and include delineated locations within which the topographic features will <br />be located on appropriate PMT maps, such as Maps 19, for the original permit area, <br />and Map 19A, for the South Taylor Area. <br />Topsoil [(2.05.(2Zd and 4.06j <br />2. Table 2.05-1 presents the permit area topsoil balance as of December 2005, for remaining <br />portions of the original permit area (pre-PR-2). The table has not been updated to reflect <br />projected topsoil availability and replacement volumes, acres, and average replacement <br />thickness for the South Taylor expansion area [average replacement thickness of 19.8 inches <br />for the South Taylor expansion area is listed in Section 2.05.4(2)(d), page 104, of the South <br />Taylor Area narrative (Volume 12)]. <br />Please provide an updated Table 2.05-1 to reflect current status of the various <br />categories listed for the original permit area. In addition, please provide a new table or <br />supplement to Table 2.05-1 to reflect current projections for the South Taylor Area, <br />based on actual volume of topsoil salvaged to date, acreage disturbed, projected <br />volume of in-place topsoil yet to be salvaged, and acreage yet to be disturbed. <br />Narrative of Section 2.05.4(2)(d) in Volume 12, should be updated as warranted to <br />correspond to current projections and to conform with revised topsoil replacement <br />narrative in Volume 1. <br />3. The amended reclamation plan includes discussion of variable topsoil replacement thickness <br />as a major element to enhance vegetative diversity and woody plant density on the reclaimed <br />landscape. Amended narrative correctly notes that relevant Federal rules [30 C.F.R. <br />816.22(d)(1)(i)] were recently amended to explicitly allow for replacement of variable <br />topsoil thicknesses, to the extent that such variations help meet the specific revegetation <br />goals identified in the permit. The corresponding State rule [4.06.4(2)(a)] has not been <br />revised, and specifies that topsoil and other [plant growth] materials shall be redistributed in <br />a manner that: <br />achieves an approximate uniform, stable thickness consistent with approved <br />postmining land uses, contours, surface water drainage systems and <br />requirements of the vegetation proposed to be established. <br />The Division has interpreted this rule as allowing for planned variation in topsoil <br />replacement thickness when the postmining land use is rangeland or wildlife habitat. The <br />rationale for variable replacement thickness is to more closely reflect the variation in topsoil <br />thickness and substrate conditions that existed prior to mining, to favor the establishment of <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 2 <br />