2009-08-13_PERMIT FILE - C1981019A (3)

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1) delineation of all post-2008 post-mining acreage exhibiting slopes 10% or flatter; 2) elimination of all small, isolated, or impractical areas for targeting this community; 3) implementing "banding" (alternating strips of grassland versus shrubland) procedures on large units with long slopes that might otherwise lead to excessive "snowmelt" erosion; and 4) assuming 50% shrub establishment success (i.e. sufficient density) on the acreage that actually receives shrub conducive metrics. Please refer to Map 44 for a visual representation of areas that are < 10% slope at Colowyo Mine according to the current PMT surface. Critical to the adoption of this approach is the need for Colowyo to be allowed to deviate from the plan in instances where plan maps or specifications do not reflect "on-the-ground" reality, and to the contrary, when opportunities for adding unplanned supplementary areas targeting shrub establishment present themselves. By acceptance of this new approach, Colowyo will be granted the flexibility to take advantage of day-to-day opportunities to promote shrub establishment and be able to option out of planned areas if site conditions prove significantly different than anticipated. Such flexibility will in no way be allowed to circumvent the requirement to maintain a proper life-of-mine topsoil balance and overall plan objective to improve shrub establishment. All significant deviations from plan maps and expectations will be documented and submitted in the Annual Reclamation Report. In this manner, as well as documentation through bond release evaluations, CDRMS will maintain authority over any such deviations. Related to this flexibility and as presented in revisions to Section 4.15, Colowyo commits to revised woody plant density success criteria for Phase III bond release for 2008 and later reclamation, that are somewhat less stringent than the original requirements, and are significantly less stringent for pre-2008 reclamation, but are ecologically defensible and appropriate. This commitment is in the interest of promoting the momentum of the bond release process and the pursuit of a "land-use" based reclamation program. Furthermore, this commitment on the part of Colowyo is based on the fact that the best reclamation science (30+ years ago), and significant financial expenditure went into implementation of the previous reclamation plan (and development of success criteria), and that recent experience and advancements in reclamation science now dictate less stringent requirements for a 10- year bond responsibility period. In other words, the original woody plant density success criterion was developed without sufficient experience, knowledge, or empirical evidence and as such was established at too high a level over too short a time period. In effect, this will amount to the waiving of the previous standards and the adoption of the new proposed standards. At the appropriate time post TR-72 approval (by August 2012), a re-evaluation will be conducted to resolve M issues involving pre and post mining land uses, AVF status, reclamation plan and AVF restoration of essential hydrologic functions for the Gossard Loadout area. 2.05-45 Revision Date: 3/14/08 Revision No.: TR-72