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well in advance of any topsoil laydown activities taking place. Colowyo has <br />committed to replacing at least the permitted allocation of topsoil to each <br />reclamation unit of either 8 or 19.5 inches depending on the location of the <br />unit. The only exception to this is the Sagebrush Steppe areas which have <br />already been identified. <br />Please clarify and specify the different topsoil replacement zones and their <br />respective replacement depth in the permit text where they are addressed. Please <br />provide this text to the Division for review. <br />Colowyo's Response: <br />Colowyo has agreed to annually provide the Division with substantial information to <br />demonstrate compliance with every reclamation block moving forward as it pertains to <br />variable topsoil depth verification. The language proposed by the Division is not <br />necessary to ensure biologically significant diversity in the depth of topsoil replaced on <br />reclamation units moving forward. <br />2. Based on the discussion of more quantitative topsoil replacement zones in <br />question 1 above, please change the "Generic Cross-Section for Topsoil <br />Replacement Depths Across a Typical Drainage", shown on Page 2.05-46, to <br />conform to these replacement depth zones. Please include a generic cross-section <br />for both the West Pit and the South Taylor Pit, using the pit specific replacement <br />zones in the appropriate cross-section. <br />Colowyo's Response: <br />Colowyo has described in detail how it will re-apply topsoil in the Sagebrush <br />Steppe areas. In addition the "Generic Cross-Section " is meant to apply to all <br />reclamation areas. The topsoil balance of each reclamation unit will depend on whether <br />it is in the "original " permit area (East Pit, West Pit, Section 16, South Facilities) or <br />South Taylor, which will dictate the allocated volume of topsoil to be applied for each <br />reclamation unit. The Division and Colowyo will be able to confirm the volume of topsoil <br />replaced and the depths to which it has been applied through load counts and on the <br />ground verification as defined in the text. Colowyo has agreed to annually provide the <br />Division with substantial information to demonstrate compliance with every reclamation <br />block moving forward as it pertains to variable topsoil depth verification. <br />3. On Page 2.05-46 Colowyo states that "(t)opsoil will then be redistributed to an <br />average or variable replacement depth..." (emphasis added). Since the focus of <br />the topsoil replacement efforts in the West and South Taylor Pits at the Colowyo <br />Mine is now variable topsoil replacement depths to enhance species diversity, the <br />statement regarding "average replacement depth" appears to be contradictory. <br />Please clarify the statement on Page 2.05-46 regarding average topsoil <br />replacement depths.