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example would be to create other sites with extremely deep topsoil depths. These sites would ideally <br />benefit woody species like aspen and chokecherry" (emphasis added). Based on the DOW <br />comments from the 7 August 2006 letter, DOW believes that there needs to be a concerted effort to <br />establish aspen and tall mountain shrubs at the Colowyo Mine. <br />The DOW's comment letter dated 5 July 2007 (sent in response to RN-05) reiterated the issues raised <br />in their 7 August 2006 comment letter (for PR-02). The letter began "Please refer to the attached letter <br />dated August 7, 2006. In that letter, the following points were discussed specific to reclamation efforts <br />on newly disturbed lands... (r)eclamation efforts need to continue to focus on reestablishment of a <br />shrub community primarily consisting of Gambel's oak, serviceberry and snowberry" (emphasis <br />added). <br />The issues relating to the reclamation plan, including variable topsoil replacement and reestablishment <br />of aspen and mountain shrub communities were not resolved in PR-02 or RN-05 and the Division <br />attached Stipulation 8 to the Colowyo Permit which states: <br />STIPULATION 8 <br />NO LATER THAN 15 MARCH 2008 THE COLOWYO COAL COMPANY SHALL <br />SUBMIT A TECHNICAL REVISION TO THE DIVISION CONTAINING A <br />COMPREHENSIVE RECLAMATION PLAN FOR THE EAST PIT, WEST PIT, SECTION <br />16 PIT, SOUTH TAYLOR PIT, FACILITIES AREA, GOSSARD LOADOUT AND ALL <br />REMAINING DISTURBANCES AT THE COLOWYO MINE. THE REVISION WILL <br />ELIMINATE OUTDATED METHODS OF RECLAMATION THAT ARE CURRENTLY <br />USED AT THE COLOWYO MINE. FURTHER, THE REVISION WILL ADDRESS <br />DIVISION CONCERNS REGARDING REVEGETATION, SOILS HANDLING AND <br />SPECIES DIVERSITY SUCCESS STANDARDS, ETC. TO MEET THE CURRENT POST- <br />MINING LAND-USE. CONSULTATION WITH THE DIVISION, THE COLORADO <br />DIVISION OF WILDLIFE, THE BUREAU OF LAND MANAGEMENT AND OTHER <br />APPROPRIATE AGENCIES WILL BE NECESSARY. <br />Stipulation 8 was, complied with on 14 March 2008 with the submittal of Technical Revision 72. <br />Again, when the Division deemed TR-72 complete letters requesting comments were sent to various <br />government agencies, including the Colorado Division of Wildlife (DOW). The DOW responded with <br />comments for TR-72 on 7 March 2008 (this letter was received by the Division on 14 April 2008 so it <br />was probably erroneously dated 7 March 2008 instead of 7 April 2008, this letter is attached). In the <br />letter DOW states "...CDOW recommends the mine establish a minimum of 2 sites specifically <br />targeted at aspen/chokecherry establishment. These sites should be a minimum of 20 acres in <br />size and should have topsoil depths of at least four feet" (emphasis added). <br />After 15 months and four adequacy reviews, TR-72 remained outstanding, with two issues remaining <br />unresolved. One issue was the variable topsoil replacement at the Colowyo Mine, which is being <br />addressed with Technical Revision 82 and the other is the aspen and mountain shrub plots, which is <br />supposed to be addressed with Technical Revision 84. The question that remained unresolved from <br />TR-72 was question 13, which reads as follows: