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A significant portion of the Gossard Loadout disturbance appears to be located within the boundaries of <br />the Wilson Creek Alluvial Valley Floor. Both the AVF and non-AVF disturbance areas associated with <br />the loadout are on relatively level terrain at significantly lower elevation than pit area disturbances. <br />Areas adjacent to the loadout are currently classified as dry cropland (small grains), but in the past, some <br />of these lands were apparently flood irrigated. For these reasons, the postmining land use of <br />Rangeland/Wildlife Habitat that is applicable to the upland areas within the Colowyo permit area, as <br />well as the 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 and proposed <br />postmining land uses, and provide a detailed revegetation plan including proposed revegetation <br />success standards as appropriate. For those portions of the Gossard Loadout facilities within the <br />AVF boundary, please include a discussion demonstrating how the proposed <br />reclamation/revegetation plan will restore the Essential Hydrologic Functions of the alluvial valley <br />floor. <br />Colowyo's Response: <br />Premining land uses associated with anything but grazingland and wildlife habitat were for all <br />practical purposes eliminated by the catastrophic runoff events of 1983-1984. The resulting down <br />cutting of the Wilson Creek stream bed have rendered any re-establishment of pre-mining conditions <br />impractical and as the events were unrelated to mining would be an unjust burden upon Colowyo to <br />attempt to re-establish the Essential Hydrologic Functions of any alluvial valley floor that may have <br />existed in the past. <br />Discussions with Division staff in the recent past involving the Gossard Loadout as related to <br />Collom permitting provided an informal conformation that this area is not considered an alluvial valley <br />floor under present conditions. Any required modification of past designations can be initiated in a <br />timely manner if needed. <br />Colowyo believes that it would be appropriate for the re-establishment of a grazingland <br />reclamation regime in the Gossard Loadout area using the same mix as proposed for the higher <br />elevation areas. This should lead to a similar mosaic of sagebrush steppe and grazingland land uses <br />that existed premining, and is appropriate given the overall focus of the re-establishment of these two <br />post mine land uses across the entirety of the reclamation surface. <br />Colowyo respectfully suggests that the requested modifications to the future reclamation of the <br />Gossard Loadout footprint be put on hold until such a time as the Division and Colowyo can have a <br />more formal in depth discussion and agree upon a path to resolve the technical aspects associated with <br />this issue. Ample time should be available to resolve this issue due to plans to utilize this facility <br />indefinitely. <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 sagebrush <br />steppe targeted slopes of 10% or less. To provide the necessary minimum acreage of areas that will be <br />required to meet the sagebrush steppe targeted revegetation success standards (minimum of 20% of post- <br />2008 seeded areas), it may be necessary to include areas of steeper slopes (perhaps up to 15% gradient).