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s <br />• Another... technique that may be used in... Sagebrush Steppe would be the <br />development of... topsoil "snow fence "berms. <br />• The primary... element... is the ability to replace variable topsoil depths... depending <br />on site-specific needs, the discretion of the field construction supervisor, and the <br />capabilities (or lack thereofi of available materials and equipment. <br />The only real commitments in the above (given the operator's use of "may" and "at the <br />discretion of...") are that soil would be replaced in lifts less than 8 inches thick on ridgetops <br />in grazingland areas, and gradually thicker moving down the slope; on sagebrush steppe, soil <br />would be replaced in lifts less than 8 inches thick except along drainages, where thickness <br />would be greater than 8 inches. <br />The operator also included a list of practices that would not be implemented; specifically, <br />topsoil would not be: <br />• "buried in place" in the footprint of existing stockpiles. <br />• placed without adequate metrics in place to accurately estimate volumes placed within <br />each reclamation unit... <br />• placed indiscriminately ... in a manner that does not serve a specific defendable <br />purpose regarding vegetation type establishment... <br />The amended plan is an improvement over the original proposal, but still does not provide the <br />level of detail and commitment necessary to demonstrate compliance with regulatory <br />requirements and land use/community type objectives. Additional details will need to be <br />provided, to ensure that topsoil will be redistributed to achieve an approximate uniform, stable <br />thickness consistent with postmining land uses and vegetation requirements, and to ensure <br />ecologically significant variation in replacement thickness across the landscape. The value of <br />significant (planned) variation in replacement thicknesses has been emphasized in discussions <br />among the Division, DOW, and the operator since well prior to submittal of TR-72. Were the <br />Division to approve the plan as presently laid out, it is not clear what we would be approving, <br />except in the most general way (in some areas replacement thickness would be less than 8 <br />inches thick and in other areas replacement thickness would be greater than 8 inches thick). <br />We have given this matter considerable thought, and have come to the conclusion that, to be <br />approvable, the plan will need to specify topsoil replacement thickness average and range for <br />delineated or narratively defined topographic sites, within each defined land use/vegetation <br />community. Because of the wide disparity regarding available topsoil volume between the <br />post 2008 "original permit area" reclamation units (8" over-all average replacement thickness) <br />and the South Taylor Area reclamation units (19.8" over-all average replacement thickness), it <br />will be necessary to present, in effect, two separate plans, one for the original permit area <br />units and one for the South Taylor units. The plans would be similar in concept but would <br />differ in specifics, and might best be presented in two tables, one for South Taylor and one for <br />Original Permit Area. Land use/vegetation type categories within each table would logically <br />include Grazingland, Sagebrush Steppe, and Aspen/Chokecherry (possibly limited to South <br />Taylor). Topographic site categories would logically be defined by slope position (e.g. ridges <br />3