2009-12-11_REVISION - C1981019 (3)

Home Browse Search

< 10% across the entire mining unit, including the East Pit, West Pit, Section 16, South facilities, and South Taylor. Based on the elimination of certain areas that are in the bottom of drainages or too small in nature to manage separately, most of the Sagebrush Steppe designated areas will receive an application of an average offour to six inches of topsoil and will be seeded to the Sagebrush Steppe seed mix. All other areas in the West Pit, East Pit, South Facilities and Section 16 will receive the balance of "unused" topsoil and will be subject to the Generic Cross-Section provided in Section 2.05 with gradually thicker topsoil from the interface of the Sagebrush Steppe areas to the rock drain structures (if applicable) in the bottom of drainages. As discussed in the text, Colowyo willfully document and explain how and why areas received any other volume within each reclamation unit other than the 8 inches or 19.5 inches discussed for maintaining topsoil balance. The Division will also receive documentation on depth and location of measurement with the Annual Reclamation Report for each reclamation unit/polygon. b. For the South Taylor Area, the plan will include at least three primary replacement zones of defined replacement thickness range and a pit-wide average. Average replacement thickness for the shallow replacement zone will be no less than 4 inches. Average replacement thickness for "medium thickness" zone will exceed average thickness of "shallow thickness zone" by at least 10 inches. Average replacement thickness for "thick soil" zone will exceed average thickness of "medium thickness" zone by at least 18 inches. Thick soil replacement zones will include locations where slope exposure and moisture conditions would potentially be favorable for establishment of aspen, chokecherry, and associated species. Colowyo's Response: b) The Generic Cross-Section provided in Section 2.05 applies to the South Taylor area equally well as the original permit area. As Colowyo discusses repeatedly in the text, an average of 19.5 inches of topsoil will be redistributed in a logically gradually thicker layer to the edge of any rock- lined drainage structures in the bottom of the drainages. The "zones " suggested by the state are not practical to implement in the field for compliance purposes and are unnecessary to meet the goal of biologically diverse topsoil depths. As discussed in the text, Colowyo willfully document and explain how and why areas received any other volume within each reclamation unit other than the 8 inches or 19.5 inches discussed for maintaining topsoil balance. The Division will also receive documentation on depth and location of measurement with the Annual Reclamation Report for each reclamation unit/polygon. The Division, according to Colowyo's proposal will be fully informed of Colowyo's topsoil redistribution intentions