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prior to the first major snowfall event; 9) placement of thin layers of topsoil over overburden; 10) possible <br />placement of zero topsoil; 11) possible placement of thin layers of overburden over topsoil; 12) use of <br />specialized seed placement equipment to obtain correct planting depths; 13) use of seedbed preparation <br />equipment and techniques to encourage sagebrush emergence; and 14) interseeding of additional grasses <br />and/or forbs (only where necessary) following a period of 2 — 3 years of growth by shrubs. All of these <br />possible techniques / metrics are designed to diminish the competitive advantage of grasses, at least in the <br />early stages of establishment and growth. The primary "foundation- building" element for this approach is <br />the ability to replace variable topsoil depths and/or quality of soil materials depending on site - specific <br />needs, the discretion of the field construction supervisor, and the capabilities (or lack thereof) of available <br />materials and equipment. <br />The following practices will not be promoted or practiced at Colowyo with respect to the topsoil resource: <br />1) Topsoil will not be "buried in place" within the footprints of existing stockpiles in order to reduce the <br />amount of resource to be moved and placed on reclamation areas. 2) At no time will topsoil be placed <br />without adequate metrics in place to accurately estimate volumes placed within each reclamation unit to <br />ensure an accurate accounting of the topsoil balance. 3) Topsoil will not be placed indiscriminately <br />within reclamation units in a manner that does not serve a specific defendable purpose regarding <br />vegetation type establishment or location within the reclamation unit or localized watershed. <br />In summary, application of PERA on "shrub- favorable areas" would be based on the community <br />development contributory factors of: 1) soil quantity, quality, and replacement depth; 2) aspect, slope, and <br />landform; 3) documented and expected performance of various floral species; 4) revegetation metrics; and <br />5) the target post- mining land use. In this manner, reclamation and resultant developing communities will <br />be encouraged to follow a more natural path to maturation and successional progression as opposed to <br />more historically utilized grassland favorable approaches that should only be applied to the remaining <br />60% to 80% of reclaimed ground (sloping areas). However, there will likely be instances, if not an <br />overall need, to incorporate managerial practices to encourage or protect positive recruitment to the shrub <br />populations. Such management may include the following steps: <br />Use of elevated quantities of sagebrush seed within the grassland target areas, <br />and placement of that seed in a manner to encourage sagebrush emergence. <br />Use of limited livestock (cattle) grazing to select against grasses and for shrubs <br />and forbs. <br />Use of elk -proof fencing to preclude access into large blocks of maturing shrub <br />populations, especially core areas. <br />Use of hunting pressure to reduce elk utilization of new reclamation where it can <br />be incorporated in a safe manner given proximity to active mining. Develop special seasons <br />in concert with CDOW for management of "refuge" elk. For obvious reasons, any activity in <br />this regard would have to be designed and approved for implementation in accordance with <br />applicable statutes. Furthermore, approvals from appropriate agencies (CDOW, MSHA, etc.) <br />will be obtained as necessary. <br />Rule 2 Permits 2.05 -21 Revision Date: 6/11/12 <br />Revision No.: RN -06 <br />