2012-09-06_REVISION - C1981019 (2)

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(CDOW) is on record as being supportive of this level of establishment based on their review of the habitat to be disturbed and the overall goals of the proposed reclamation plan. Colowyo is specifically targeting approximately 600 acres (all areas on the proposed post mine topography (PMT) < 10% slope) of core sagebrush steppe for establishment, which is 250 acres above and beyond the regulatory requirements. On -site studies have identified improved shrub establishment on reclamation areas exhibiting shallow topsoil depths (average of 4 inches). All areas targeted for core sagebrush steppe establishment will receive this shallow topsoil application. The reclamation seed mix should also benefit from the elimination of aggressive grass species and an overall reduction in grass components (bunchgrasses are included and aggressive sod formers have been eliminated). • Colowyo has created a proposed seed mix for the grassland targeted areas (all areas of the proposed PMT > 10% slope) that contains a large component of shrub seed (predominately Artemesia tridentate) and expects the development of substantial shrub communitites on areas > 10% slope as well that will be identified and counted towards Colowyo's sagebrush steppe acreage requirements. Variable topsoil depths will be applied in grassland targeted areas to more closely mimic pre -mine topsoil resource distribution and encourage the development of a diverse mix of plant communities based on differential aspect and elevation conditions as reclamation activities progress. • Specific field trials are scheduled to be conducted in the Collom Expansion Area to attempt to identify practices that encourage the re- establishment of the Tall Shrub plant community. To date, efforts to establish this plant community at Colowyo have been ineffective despite best management practices and efforts utilizing seed, containerized plantings, saplings, and live transplant of mature individuals. As reclamation science continues to advance, additional efforts are being conducted to achieve some level of success moving forward and Colowyo is committed to supporting this process. • The short term loss of Greater sage - grouse habitat within the disturbance area is portrayed most effectively by the attached Map 23 Mine Plan. The largest impact to sage grouse populations would be during facility /initial boxcut development within the first five years of mining Based on the 2011 survey, no leks, Greater sage - grouse or Columbian sharp -tail grouse are targeted for direct physical disturbance and should be left intact for future use post mining activity. • Beyond the measures already in place through cooperation with CDOW, Bureau of Land Management (BLM), and local landowners, Colowyo would convert approximately 274 acres of wheat fields surrounding the Gossard Loadout facility to a conservation reserve program (CRP) equivalent plant community that would act as additional habitat for sage grouse, mule deer, and elk. • Re- evaluation of grazing leases in the Morgan Creek Ranching for Wildlife Area to identify specifically targeted improvements that would benefit local sage grouse populations. • Evaluation of livestock grazing utilization of specific riparian areas in the Morgan Creek Ranching for Wildlife Area and subsequent scheduling of possible water development fencing or other relevant management practices that would positively impact local sage grouse populations. • Evaluation of the Axial Basin Coordinated Resource Management agreement (Cooperative agreement between Colowyo, BLM, CDOW, and other local landowners to Page 11