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Colowyo's Response: <br />Comment noted - corrections to text made as appropriate. <br />31. It was common practice several years ago at the Colowyo Mine to rip, scarify or otherwise roughen the <br />recently replaced topsoil at the mine prior to reseeding. This was often accomplished by using a dozer <br />to rip the topsoil on contour. The main benefit of this practice was to reduce the erosion potential from <br />rain and spring runoff. A secondary benefit is that the pond receiving the runoff the Prospect Pond, in <br />this case) will not receive as much sediment. This practice has been discontinued in the last few years. <br />On site inspections this spring (see in particular the 16 April 2008 inspection report) it was evident that <br />water is flowing uncontrolled over the recently reclaimed surface, causing extensive rilling. This year <br />the snowmelt was pretty gradual and there was still some damage to the reclaimed surface. In years <br />where the snowmelt is faster, the results could be catastrophic. The Division would like to see this <br />practice restarted and requests that Colowyo include a commitment to use surface roughening <br />techniques on all areas where topsoil has been replaced at the Colowyo Mine. <br />Colowyo's Response: <br />Colowyo will make the commitment to roughen the areas to be seeded to the grazingland mix at <br />the time immediately prior to seeding. Colowyo cannot commit to roughening the areas targeted for <br />potential sagebrush steppe establishment for seedbed preparation reasons as the conditions present on <br />roughened topsoil areas are counterproductive to shrub establishment because you lose the ability to <br />place shrub seed where it will effectively germinate and establish. It is Colowyo's opinion that this <br />condition was one of the major reasons why shrubs found it difficult to establish in the past and why we <br />have insisted on only attempting targeted shrub establishment on areas <10% in this revision. <br />Colowyo concurs that the use of contour furrows along slopes along the contour are a practical <br />tool and will be utilized in future reclamation efforts. They will be established in instances where long <br />slopes of current year reclamation are unbroken by any other associated features. These furrows will <br />be field fit year to year as the reclamation progresses and reported in the appropriate manner at <br />intervals negotiated between Colowyo and the Division. <br />All revised materials and an index of changes sheet are included in this packet with the exception of Map 44 <br />which is being mailed to you today under separate cover by Tom Peterson. If you have any questions or require <br />additional information, please feel free to contact me at (970) 824-1531. <br />Sincere y, <br />Kurtis Blunt <br />Environmental Engineer <br />Encl. 3 copies <br />Cc: file CF 1.1.2.61