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In the item response, the operator stated "...the topsoil resource will be <br />completely documented [in the South Taylor area] well before any topsoil <br />placement activities will be required. Table 2.05-1 could be updated during <br />permit renewals for example." <br />The response is acceptable to the Division, with the condition that Table 2.05-1 <br />and associated text regarding topsoil volumes available for replacement in the <br />South Taylor area be updated as warranted upon conclusion of South Taylor <br />salvage operations, and prior to initiation of South Taylor topsoil replacement. <br />Please include an appropriate permit commitment to update Table 2.05-1 to <br />incorporate South Taylor area soil salvage volumes, and associated narrative <br />regarding South Taylor soil replacement, upon conclusion of South Taylor <br />salvage operations and prior to initiation of South Taylor topsoil replacement <br />operations. This commitment could logically be included as a footnote to <br />Table 2.05-1. <br />3. In this Item, the Division had requested various amendments to provide a more <br />detailed, internally consistent plan containing commitments that would ensure <br />compliance with regulatory requirements and which would ensure significant <br />variation in soil replacement thickness. Variation in soil replacement thickness is <br />viewed by the Division as a tool to enhance vegetative diversity and meet the <br />needs of various reclaimed communities, including the major postmining <br />communities of sagebrush steppe and upland grassland (grazing land), and minor <br />communities including tall mountain shrub/aspen woodland. The Division views <br />attempts to establish components of aspen woodland and mountain shrub habitat <br />using the best current technology to be important, both from the standpoint of <br />establishing "footholds" from which these community types can potentially <br />spread in the future, and in order to gain knowledge regarding establishment of <br />aspen and mountain shrub species that can be applied to future mine disturbances <br />in these community types (for which the state of the science is still immature). <br />Colowyo's proposed amendments made in response to this item addressed some, <br />but not all of the Division's concerns. Amended narrative includes the following <br />statements: <br />• topsoil will be...graded to an average or variable replacement depth <br />following the general rule of thin topsoil (0-8) inches on ridge tops to <br />gradually thicker topsoil moving down the slopes to the drainage bottoms <br />for the grazingland land use targeted areas. <br />• Where sagebrush steppe revegetation will be targeted, Colowyo would <br />apply shallow lifts of topsoil (<8 inches, ideally 4-6 inches). To maintain <br />topsoil replacement balances, thicker lifts of topsoil (>8 inches, <br />occasionally up to 3-4 feet) can be placed along the groin of opposing <br />slopes (drainage-ways).