2009-01-29_REVISION - C1981019 (4)

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Colowyo Mine TR-72 PARS 29 January 2009 Page 3 of 8 would fit in the permit text under the topsoil heading (Pages 2.05-46 to 49). This documentation will be important if topsoil depth is varied within a single reclamation unit, as described on Page 2.05-48. Additionally, Colowyo will need to include a new topsoil balance chart that details the replacement depths within each unit. This commitment and map/text in the ARR will help document that Colowyo has met the topsoil replacement requirements necessary to achieve Phase II Bond Release. Finally, the Division is requesting that Colowyo dig representative test holes in the newly spread topsoil to ensure that the proper depth or range of replacement depths is being met. This is critical given the innovative approach in topsoil replacement that Colowyo is proposing. The test holes should be spaced appropriately to get an adequate sample size but should be spaced no farther apart than one hole every 500 feet. 4. Item Resolved in first adequacy review. Revegetation [(2.05.4(2)(e) and 4.151 Supplemental Introduction in amended Section 2.05.4 5. In the 26 June 2008 letter, the Division requested that Colowyo amend the woody plant density standards section of the narrative to conform with specified criteria pertaining to minimum shrub steppe acreage, shrub density within "core" and "ecotone" areas, and certain species limitations, and further requested that provisions allowing for "positive recruitment" based standard reductions be eliminated. In their 28 July 2008 responses, Colowyo proposed modified criteria that did not fully comply with the Division's request. The Division believes that the criteria laid out in our 26 June 2008 letter are appropriate, with only minor adjustment, based on discussion with DOW staff on 20 January 2009, consideration of currently approved woody plant density standards at other surface mines in northwest Colorado, and shrub establishment success that is reasonable to expect using appropriate native seed mixes, soil handling, cultural, and management practices. The Division believes further reduction with respect to shrub steppe acreage or the numeric density standard for the post-2008 areas would not be appropriate, given the original understanding that wildlife habitat with a significant shrub component would be the major focus of reclamation efforts on these lands. The Division will agree to the request that fourwing saltbush shrubs be allowed to count toward the density standard, to the extent that no more than 20% of countable shrubs be fourwing saltbush. As such, the woody plant density success criteria will need to be stated as follows: