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Provide a reclamation map showing proposed topsoil thickness averages <br />and ranges for delineated sites, along with planned location and extent of <br />various enhancement treatments mentioned in the reclamation plan <br />narrative, and; <br />• Commit to conduct annual soil replacement thickness sampling; and to <br />provide an Annual Reclamation Report map and table documentation of <br />soil replacement thickness. <br />Colowyo's most recent submittal does not provide the necessary details and <br />commitments requested. In the cover letter and revised narrative, Colowyo <br />indicates that they would track soil replacement volumes, but not replacement <br />depth/thickness. Regarding planned variable thickness soil replacement, they <br />refer to a new "profile description diagram" on amended page 2.05.4-46. The <br />referenced diagram is a generalized cross-section of a hypothetical reclaimed <br />watershed, from ridgeline to ridgeline, showing 0 to 6 inch soil thickness on <br />ridges and upper slopes, 6 inch thickness to "as much as needed for topsoil <br />balance" on lower half of slopes, and 0 to 6" adjacent to the channel. In the <br />amended text, the diagram is described as "a visual representation of the general <br />goal..." In the cover letter, Colowyo indicates that "deviations from the spirit of <br />the diagram will be discussed with the Division prior to completion of topsoil <br />laydown activities in a given reclamation unit..." Amended narrative regarding <br />topsoil replacement refers to "average or variable replacement depth following the <br />general rule of thin topsoil (0-8) inches on ridge tops to gradually thicker topsoil <br />moving down the slopes..." <br />The Division does not consider the amended plan to be adequate, as it does not <br />provide the level of detail or commitment necessary to demonstrate that topsoil <br />would be redistributed to achieve "an approximate uniform, stable thickness <br />consistent with approved post-mining land uses, contours, surface water drainage <br />systems and requirements of the vegetation proposed to be established" as <br />required by Rule 4.06.4(2)(a). The Division does not interpret the regulation <br />language to require replacement of a single, uniform thickness across the entirety <br />of a reclaimed area, but does interpret the language to require replacement of a <br />defined approximate uniform thickness within delineated portions of a reclaimed <br />area. <br />For the post-2008 portions of the original permit area, the Division would accept a <br />variable replacement plan incorporating narrative and mapping commitments <br />adequate to ensure replacement of a significant acreage of at least two soil <br />replacement zones, as follows: <br />• a "thin soil" zone, with a 0 to 8 inch replacement range and a 4 inch <br />minimum average thickness, and; <br />• a "thick soil" zone, with an 8 to 16 inch replacement range and a 10 inch <br />minimum average thickness.