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19. Colowyo has not provided any information regarding additional treatments that might be used <br />on the aspen and tall mountain shrub test plots. The Division believes that treatments such as <br />leaving the overburden and topsoil in a very loose (uncompacted) condition, fertilizing <br />transplants, mulching or the use of netting in the areas may enhance the growth of the desired <br />communities and yield better success. Additionally, since the seeding rates of the native <br />grasses are being reduced, there will be a need to further stabilize the reclaimed surface prior to <br />the establishment of the grasses and trees or shrubs. Please provide the Division with more <br />detail regarding additional measures that will be used on the aspen and tall mountain <br />shrub test plots to better control erosion and enhance the growth of the desired <br />communities. <br />20. Colowyo has not provided the Division with a plan for the monitoring of the proposed aspen <br />and tall mountain shrub test plots. The monitoring of these plots will be essential to determine <br />whether the plots are successful. Please include a monitoring plan for the test plots. <br />Additionally, please include a description of how Colowyo will report the results of the <br />monitoring to the Division. <br />21. Finally, the Division will approve the field trial proposal, only with the condition that larger <br />scale plantings will be incorporated into the reclamation plan for the South Taylor area, based <br />on results observed and documented in the field trials. Please provide amended narrative <br />within TR-84, which commits to final reporting and assessment of field trial results no later <br />than the end of 2016, and commits to incorporation of thick soil and thin soil aspen and tall <br />shrub planting sites into the permit for implementation in the South Taylor area, no later than <br />the end of 2017. The amended narrative will need to confirm that the aspen and tall shrub <br />plantings will be conducted in accordance with the provisions outlined in Stipulation 13, <br />subject to modification based on assessment of field trial results by CDRMS and CDOW. If <br />Colowyo provides such commitment in the amended narrative, the Division will revise the time <br />frames of Stipulation 13 accordingly, and will further revise Stipulation 13 to reference <br />potential future modification of the aspen and tall shrub planting plans based on field trial <br />results. <br />This concludes the preliminary adequacy review for the Colowyo Mine's Technical Revision 84. The <br />proposed decision date for this revision is 22 June 2010. The Division requests Colowyo's responses <br />no later than 1 June 2010. Please call me at (303) 866-3567 X8145 with any questions. <br />Sincerely, <br />James R. Stark <br />Environmental Protection Specialist <br />cc: Sandy Brown <br />attachments