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<br /> <br /> <br />(4) <br /> <br />the W.J. mixture of Western Wheatgrass, Crested Wheatgrass <br />~. <br />. Cicer <br />Milk Vetch and Dry Land Alfalfa is not a diverse culture of native <br />species as required by Subsection 515 (b) (19) of PL 95-87. The <br />applicable standard, however, is Section 516 (b) (6), which does <br />not require a native seasonal variety for undcrNround mines. IC <br />is interesting to note that this mixture was fir ;t suggested to <br />CWI by the Soil Conservation Service of U.S.U.A.. In any event, <br />the criticism is irrelevant because CWI's consultant intends to <br />use the P.E.F. Mixture on all slopes and the SCS mixture on all <br />flat bench areas. The P.E.F. [9ixture was developed through the <br />assistance of the Agronomy Department at Colorado State University <br />and the SCS Mixture was developed by the SCS. <br />Criticism was also leveled at the mining plan's "failure" to <br />specify a recommended mulching technique. A discussion of various <br />mulching techniques can be found in Section 4.4.5.5 of the mine plan. <br />According to Phillip Flores, the following specific mulching <br />procedures will be utilized: <br />s~lo~es - fertilizer, hydro seed, hydro mulch with wood <br />celulose fibers ,.surficial biodegradable erosion control <br />material (jute mesh or excelsior mats) <br />bench areas - 12" of subsoil then topsoil, fertilizer, <br />Z~dro see and hydro mulch. <br />As reclamation efforts develop, different combinations of techniques <br />will be used to optimize results on different terrain and soil areas. <br />EPA's insistance on specifying one method for all types of slopes <br />and soil conditions is unreasonable and impractical. <br />EPA's criticism of the erosion control record of CWI is unfair <br />and extreme. CWI purchased the Orchard Valley Mine from Colorado <br />Consolidated late in 1975. Full scale mining operations on~the <br />D seam, the only seam being mined by CWI, did not begin n l late <br />i <br />~.i i~JI ~1;~i1 ii.. ,~.~,~ u, . ~ <br />