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III. COMMENTS • COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. The Laplata permit revocation site was inspected April 2,2002, at 4:20 pm. The inspection focused on appazent revegetation success, in anticipation oftevegetation sampling later this season and possible termination of DMG jurisdiction at the site. At Laplata there would be two separate areas to sample; main portal bench disturbance area on the south facing hillslope, and the smaller reclaimed sediment pond disturbance on the irrigated valley floor across the road. So early in the growing season it was difficult to judge the apparent productivity of the irrigated pasture, although it appeared to blend in well with adjacent areas, I believe the area was designated as cropland and that as such productivity is the applicable standard, although no specific standard was set. The most logical approach would be to sample productivity within the disturbed area and within a representative adjacent irrigated pasture area. We would need to secure permission from the landowner for such production clipping. The alternative would be visual assessment of apparent productivity later in the growing season, just prior to initial harvest. At the mine bench disturbance area, it will be important to define the exact disturbance boundaries, because it was a pre-law disturbance, only a portion of which was re-disturbed and reclaimed by Laplata. Some concrete foundations were left in place in the coal stockpile area at the base of the old conveyor line, and there is an occupied trailer house there presently: I believe the structures were approved for retention for postmine land use, and that no revegetation was required in the lower facilities area. Also at one end of the upper bench, there is an old portal which had apparently been bat sealed by AML, and they may have done a small amount of surface reclamation. The reclaimed upper bench supported a vegetation stand dominated by rubber rabbitbrush and crested wheatgrass; vegetative cover probably in the 30-40% range (though somewhat difficult for me to judge due to the amount of rabbitbrush present}, The vegetative cover appears to be as good as might be expected for a relatively steep south facing slope in PJ habitat, and cover is the only standard applicable to the upland disturbed areas at the mine. However, the permit specified vegetation cover standard is 70%, which would seem to be excessive given the ecological setting. The conveyor route ran down the middle of the small.valley in which the mine was situated, and a gully has eroded along the steep slope from the lower edge of the upper bench backfill down to the flat area at the base of the slope. Some geocell type erosion control material had been installed at some point at the upper end of the steep slope, but it was blown out several years ago by a large storm event (according to Warty Erickson}. Tfiere would appear to be the potential for further headcutting of the gully into the bench backfill when the next large runoff event occurs. Stabilization of the gully headcuj would appear to be warranted. The gully probably averages 2-4 feet wide and in a couple segments along a 150' length has downcut up to 4 or 5 feet deep. There is some Canada thistle along the old conveyor route.