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preparation for seeding or planting. Moreover, consistent with Rule 4.15.4 which <br />requires that soil stabilizing practices be carried out, heavy mulching has occurred on all <br />terraces and has resulted in the growth of some wheat in various areas. The seeding of <br />perennial vegetation has resulted in very good establishment in all areas where there was <br />a heavy growth of volunteer wheat. The wheat acts as a nurse crop providing some <br />shading and protection for [he perennials, as well as soil erosion protection until the <br />perennials become more fully established. The wheat is not expected to persist as a <br />significant component of the vegetative cover for more than a few years. <br />The older vegetation on CRDA-2 is spottier that that on CRDA-1, possibly due to the <br />drought and aspect of the pile. The understory grasses have not been as successful as <br />shrubs. Roadside has interseeded small parts of the pile where revegetation has not been <br />as successful or where the vegetation has died (fall 2001). From a visual and qualitative <br />standpoint, the vegetation (where mature) appears to be where it should be at this point <br />and is approaching approved standards for cover although diversity remains a concern. <br />DMG and the operator will evaluate the success of the inter-seeding over the next couple <br />of growing seasons, and the need for further investigative action will be assessed. <br />ROADSIDE <br />While this coal waste bank is the oldest pile of the three, it has the most recent <br />revegetation. Both the topsoil and subsoil cover material came from a borrow area east <br />of the Roadside Pile, on top of the plateau above the primary mine disturbance area. The <br />topsoil/subsoil depth of the Roadside bank is 18 inches, which is required in the approved <br />permit application. The DMG approved a variance from the requirement at Rule <br />4.10.4(5) that waste banks be covered with a minimum of four feet non-toxic and non- <br />combustible material following amulti-year field trial and prior to initial reclamation in <br />1994. The variance was granted due to the aspect of the slope, the lack of available cover <br />material, and a study conducted by the Roadside Mine that demonstrates 18 inches of <br />topsoil/subsoil is adequate for revegetation purposes. The study was actually conducted <br />on this waste pile. The topsoil/subsoil cover was placed in June of 2002. Thus, the <br />topsoil has been replaced to required depths in accordance with Rule 4.06.4(2}. <br />The replaced topsoil and subsoil horizons are largely indistinguishablefrom one another, <br />and sampling conducted with the operator has shown that soil quality is consistent with <br />permit criteria for topdressing and subsoil. Consistent with Rule 4.06.5, the topsoil has <br />been redistributed and "roughened," or gouged, with a track hoe to catch moisture. <br />Reclamation of the pile slopes was finished in July of 2002 with temporary barley <br />seeding, and the roughening and final seeding of the cover occurred in November of that <br />year. Reclamation of the top of the pile is to be completed by the end of 2004. <br />Because of the acid environment and nature of the parent materials in the permit area, <br />soils typically have elevated levels of salts and high sodium absorption ratios. Native <br />vegetation communities and the species included in the approved permanent seed mixes <br />are adapted to these conditions. As a result, some spotty establishment may result. The <br />seed mix consists of different grass species and shrubs including shadscale saltbush, <br />greasewood, snakeweed, wheat grass, wild rye and four-wing saltbush. Just like CRDA- <br />