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In the item response, the operator stated "...the topsoil resource will be completely <br />documented [in the South Taylor area] well before any topsoil placement activities will be <br />required. Table 2.05-1 could be updated during permit renewals for example." <br />The response is acceptable to the Division, with the condition that Table 2.05-1 and <br />associated text regarding topsoil volumes available for replacement in the South Taylor area <br />be updated as warranted upon conclusion of South Taylor salvage operations, and prior to <br />initiation of South Taylor topsoil replacement. <br />Please include an appropriate permit commitment to update Table 2.05-1 to incorporate <br />South Taylor area soil salvage volumes, and associated narrative regarding South <br />Taylor soil replacement, upon conclusion of South Taylor salvage operations and prior <br />to initiation of South Taylor topsoil replacement operations. This commitment could <br />logically be included as a footnote to Table 2.05-1. <br />3. In this Item, the Division had requested various amendments to provide a more detailed, <br />internally consistent plan containing commitments that would ensure compliance with <br />regulatory requirements and which would ensure significant variation in soil replacement <br />thickness. Variation in soil replacement thickness is viewed by the Division as a tool to <br />enhance vegetative diversity and meet the needs of various reclaimed communities, including <br />the major postmining communities of sagebrush steppe and upland grassland (grazing land), <br />and minor communities including tall mountain shrub/aspen woodland. The Division views <br />attempts to establish components of aspen woodland and mountain shrub habitat using the <br />best current technology to be important, both from the standpoint of establishing "footholds" <br />from which these community types can potentially spread in the future, and in order to gain <br />knowledge regarding establishment of aspen and mountain shrub species that can be applied <br />to future mine disturbances in these community types (for which the state of the science is <br />still immature). <br />Colowyo's proposed amendments made in response to this item addressed some, but not all of <br />the Division's concerns. Amended narrative includes the following statements: <br />• topsoil will be...graded to an 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 to the drainage bottoms for the grazingland land use targeted <br />areas. <br />• Where sagebrush steppe revegetation will be targeted, Colowyo would apply shallow <br />lifts of topsoil (<8 inches, ideally 4-6 inches). To maintain topsoil replacement <br />balances, thicker lifts of topsoil (>8 inches, occasionally up to 3-4 feet) can be placed <br />along the groin of opposing slopes (drainage-ways). <br />• On long slopes steeper than 10%, topsoil distribution using pushdown techniques <br />may be altered to facilitate thin layers near the upper shoulders of the slope, with <br />thicker layers near the bottoms. <br />• Another directive... (at the discretion of the field supervisor) will be instruction to <br />equipment operators to NOT engineer the final surface, but to leave it in a state of <br />disarray with thick and thin spots of topsoil. <br />2