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thickness variability should be more pronounced than the post-2008 portions of <br />the original permit area, due to the significantly greater volume of available <br />topsoil projected. <br />The Division understands Colowyo's concern that a variance in topsoil <br />replacement depths from those listed on a map may be a source of contention and <br />possibly result in enforcement action. The Division understands that over any <br />topsoil replacement unit there is a certain amount of variability (for example, in a <br />unit where 8 inches of topsoil is to be replaced, one area may have 10 inches <br />while another area may have only 6 inches). The Division's main concern is that <br />all available topsoil is replaced and as long as an area-wide average is maintained, <br />there are no problems. This is one reason why a topsoil replacement range would <br />be beneficial (for example, one area may have a range of 0-2 inches of topsoil, <br />another may have a range of 4-6 inches of topsoil, and so forth). Colowyo may <br />wish to add specific wording to their revised text to address this issue. <br />Please revise the cited narrative as appropriate and provide an appropriate <br />topsoil replacement thickness map or maps, pursuant to the above <br />discussion. Approximate acreage and general locations within which the <br />"soil berm", and "thick and thin disarray" practices would be applied should <br />be described/delineated. Use of snow fencing in appropriate locations to <br />enhance shrub establishment should also be addressed. <br />Additionally, Colowyo must commit, in the permit text under the topsoil <br />heading (Pages 2.05-46 to 49), to an ARR map or plate that maps the topsoil <br />depth(s) for each reclamation unit in detail after replacement. This will be <br />especially important if topsoil depth is varied within a single reclamation <br />unit, as described on Page 2.05-48. Additionally, Colowyo will need to <br />include a new topsoil balance chart that details the replacement depths <br />within each unit. This commitment and map/text in the ARR will help <br />document that Colowyo has met the topsoil replacement requirements to <br />achieve Phase II Bond Release. <br />Finally, Colowyo must commit to digging test holes in the newly spread <br />topsoil to ensure that the proper depth or range of depths is being met. This <br />is critical given the innovative approach in topsoil replacement that Colowyo <br />is proposing. The test holes should be spaced appropriately to get an <br />adequate sample size but should be spaced no farther apart than one hole <br />every 500 feet. <br />Colowyo's Response: <br />Colowyo will track the volume of topsoil applied to each reclamation unit <br />and report it within the Annual Reclamation Report each year. Colowyo prefers <br />not to engage in an intensive topsoil depth verification regime as described in the <br />Divisions' response above. As discussed with Mr. Stark, topsoil balance tracking <br />is already a component of the Annual Reclamation Report. Colowyo utilizes load