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Topsoil ((2.05.(2)(d and 4.061 <br />2. The proper footnote has-been added to Table 2.05-1 as requested. Item Resolved. <br />Depending on the extent to which actual South Taylor salvage volumes differ <br />from volumes projected in the Soil Resources section of the application, topsoil <br />replacement plan narrative details may also need to be refined prior to initiation of <br />South Taylor topsoil replacement operations, in conjunction with future revision <br />of the table. <br />3. In the 26 June 2008 letter, the Division requested further amendment of the <br />topsoil replacement plan, to provide the level of detail and commitment necessary <br />to demonstrate compliance with regulatory requirements and land use/community <br />type objectives. Additional details were requested, to ensure that topsoil will be <br />redistributed to achieve an approximate uniform, stable thickness consistent with <br />postmining land uses and vegetation requirements, and to ensure ecologically <br />significant variation in replacement thickness across the landscape. The Division <br />specifically requested a plan that would specifytopsoil replacement thickness <br />averages and ranges for delineated topographic sites, within each defined land <br />use/vegetation community, and noted that more dramatic variation would be <br />achievable (and would need to be reflected in the plan) for the South Taylor Area, <br />where the projected average soil thickness is approximately 2.5 times greater than <br />in the remaining portion of the currently approved permit area. <br />Division of Wildlife (DOW) representatives stressed during our meeting on 20 <br />January 2009, that they considered commitments for variable topsoil replacement <br />to be a fundamental element of the reclamation plan, to achieve the desired <br />vegetative diversity. They felt the best approach for delineation of varying topsoil <br />thicknesses and treatment areas would be to include a map that would define the <br />general areas and topographic features associated with defined soil replacement <br />thickness ranges and enhancement treatments (such as snow fences, soil berms, <br />etc.). <br />Revised topsoil replacement narrative on amended pages 2.05-46 through 2.05-49 <br />does not adequately address the concerns the Division has identified. The <br />Division does not accept Colowyo's argument that a plan with defined thickness <br />replacement zones is impractical because of frequent mine plan changes and <br />limitations of recovery estimates. The vast majority of soil salvage for the <br />original permit area has been completed, and salvage operations for the South <br />Taylor area will be completed prior to initiation of topsoil replacement. <br />Regardless, a defined plan based on the current topsoil stockpile volumes and <br />future recovery projections will need to be provided. A topsoil replacement plan <br />delineating soil thickness averages and ranges for defined topographic areas will <br />need to be provided, to ensure that topsoiling operations will be conducted to <br />achieve the desired ecologically significant variation in soil thickness across the <br />landscape. The Division believes that a map with delineated soil depth <br />replacement zones is warranted, and notes that South Taylor replacement