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Hills, the Division believes it is important for Colowyo to include plans for a limited number <br />of aspen and tall shrub establishment areas in appropriate site locations. <br />Please revise the reclamation plan as appropriate to address this concern. <br />14. Near the middle of page 2.05-57, there is reference to possible use of elk proof fencing in <br />certain locations, at the discretion of Colowyo's reclamation coordinator. Elk proof fencing <br />is a necessity for aspen and tall shrub plantings, and will need to be specified in the revised <br />plan to be submitted in response to Item 13, above. In addition, elk fencing has been <br />observed to promote growth and density of sagebrush stands and to allow for higher survival <br />and growth of associated high palatability species, particularly bitterbrush. <br />Please include commitment and detailed plans for provision of at least one elk fenced <br />sagebrush bitter brush seeding area, one or more fenced "rocky soil" mountain shrub <br />planting areas, and two or more fenced "thick topsoil" aspen/tall shrub planting areas, <br />within appropriate locations in the post-2008 wildlife habitat emphasis areas. <br />15. In the 3~d paragraph of page 2.05-57, there is reference to reclamation of various facilities <br />within the Colowyo permit area. While revegetation techniques and standards for most <br />facility sites would logically be consistent with those applicable to adjacent pit reclamation <br />areas, this would likely not be the case for disturbed areas associated with the Gossard <br />Loadout. <br />A significant portion of the Gossard Loadout disturbance appears to be located within the <br />boundaries of the Wilson Creek Alluvial Valley Floor. Both the AVF and non-AVF <br />disturbance areas associated with the Loadout are on relatively level terrain at significantly <br />lower elevation than pit area disturbances. Areas adjacent to the Loadout are currently <br />classified as dry cropland (small grains), but in the past, some of these lands were apparently <br />flood irrigated. For these reasons, the postmining land use of Rangeland/Wildlife Habitat <br />that is applicable to the upland areas within the Colowyo permit area, as well as the <br />associated revegetation plans and success standards, may not be appropriate for the Gossard <br />Loadout disturbance areas. <br />For all lands disturbed by the Gossard Loadout facilities, please identify premining <br />and proposed postmining land uses, and provide a detailed revegetation plan including <br />proposed revegetation success standards as appropriate. For those portions of the <br />Gossard Loadout facilities within the AVF boundary, please include a discussion <br />demonstrating how the proposed reclamation/revegetation plan will restore the <br />Essential Hydrologic Functions of the alluvial valley floor. <br />Planting and Seeding Methods in amended Section 2.05.4 <br />16. The technique of "banding" or "strip seeding" is discussed as an optional procedure on long <br />sagebrush steppe targeted slopes of 10% or less. To provide the necessary minimum <br />acreage of areas that will be required to meet the sagebrush steppe targeted revegetation <br />success standards (minimum of 20% of post-2008 seeded areas), it may be necessary to <br />Colowyo Coal Company, C-1981-019 TR-72 <br />April 29, 2008 Page 9 <br />