2008-04-29_REVISION - C1981019 - Laserfiche WebLink

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particular vegetative life forms or community types, and to enhance the potential for increased vegetative diversity on the reclaimed landscape. These concepts were discussed among Colowyo, the Division, and CDOW on various occasions and within numerous items of correspondence. There was general agreement that the amended reclamation plan should identify site locations where thin topsoils would be replaced, to favor sagebrush and certain other shrubs and native fortis, due to fact that faster growing grasses typically thrive at the expense of shrubs, when relatively deep, uniform topsoils are replaced over large expanses. Replacement of extremely thick topsoils in selected sites conducive to the establishment of aspen woodland and associated tall shrubs was also discussed. Replacement of a range of varying topsoil thicknesses over the landscape was viewed as an important strategy for achieving vegetative diversity on the reclaimed landscape. The general concepts were included in various sections of the amended text, but further refinement and specificity is warranted, to move from conceptual discussion to enforceable commitment, appropriate for inclusion in a permit. The Division has the following requests regarding topsoil replacement plans. a) In the Supplemental Introduction beginning on page 2.05-42, there is a list of 14 measures that would be implemented or considered to facilitate the establishment of a sagebrush grassland community. Several of the measures relate to variable topsoil replacement, including construction of snow catchment berms, placement of thin layers of topsoil, and possible placement of thin layers of overburden over topsoil. Following the itemized list is the following statement. The primary `foundation building" element for this approach is the ability to replace variable topsoil depths and/or quality of soil materials depending on site-specific needs, the discretion of the field construction supervisor, and the capabilities (or lack thereof of available materials and equipment. From the Division's point of view, the portion of the sentence after the first comma raises alarms, because it could be interpreted as implying that that "anything goes" with respect to topsoil replacement, and that the field construction supervisor would have freedom of choice with respect to decisions pertaining to topsoil replacement thickness. The Division doubts this is what was intended, and the Division requests that the language be deleted or properly qualified. The Division suggests the sentence be revised as follows. The primary `foundation building" element for this approach is the ability to replace variable topsoil depths and/or quality of soil materials depending on site-specific needs, as more specifically described under "Topsoil Redistribution Plan" of this section. b) On amended page 2.05-46, at the end of the 2°d paragraph of the Topsoil Redistribution Plan, narrative states that topsoil will be "redistributed and graded to an average or variable replacement depth shown in Section 4.06". This is confusing because Section 4.06 of Colowyo Coal Company, C-] 98l -019 TR-72 April 29, 2008 Page 3