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Also, we suggest that all information pertaining to bonding be <br />consolidated in Section 3.0 thereby deleting any bonding discussion in <br />this section or in Exhibit 9. <br />14. Page 2.05-36 discusses two different straw mulching rates: 2000 pounds <br />per acre for flat surfaces and 4000 pounds per acre for steeper areas. <br />Due to the harsh characteristics (steep slopes and south exposure) of <br />this site, the Division believes the entire site should be straw mulched <br />at 4000 pounds per acre. <br />15. The information in Exhibit 17 pertaining to the proposed cropland seed <br />mix should be incorporated into the text. Ai so, the text (such as pages <br />2.05-40 and 2.05-44) and Map 9 should be expanded to reflect the areas to <br />be seeded to rangeland and to cropland. <br />16. The Division is required to review the proposed seed mixtures to assure <br />that mixtures are not overly dependent upon introduced species and to <br />assess total seeding rate. The following problems were identified with <br />Table 7 which affected our review. La Plata Coal should modify this <br />table based on the following. <br />A. Timothy has 1,230,000* seeds per pound rather than the listed <br />13,000,000. <br />B. Mountain brome is a "native" grass rather than the listed <br />"introduced". <br />C. sainfoin is "common" sainfoin rather than the listed sainfoin <br />"sweetciover" with 26,000* seeds per pound rather than the listed <br />262,000. <br />*Wasser, C.H. 1982 Ecology and Culture of Selected Species Useful in <br />Revegetating Disturbed Lands in the West. U,S. Department of Interior, <br />Fish and Wildlife Service, FWS/OBS - 82/56. 347 pp. <br />17. Page 2.05-43 references the reader to Section 4.15.10 of the application <br />(pages 4.15-3 and 4.16-1) pertaining to determination of reclamation <br />success. Page 4,16-1 specifies "The Division will develop success <br />criteria during final review process". To assist La Plata Coal, the <br />Division suggests the following revegetation success criteria. <br />A. The Division agrees that the success criteria addressed in Rule <br />4.15.10 of the regulations are applicable for all areas except for <br />the sediment pond and associated diversion ditches. The Division <br />bases this position on the fact that the areas (except diversions <br />and sediment pond) were disturbed prior to the enactment of this law <br />and not reclaimed to current revegetation standards. <br />For these areas, <br />applicable. The <br />live vegetative <br />prevent erosion <br />growth medium. <br />the cover requirements of Rule 4.15.10(1) are <br />Division proposes a minimum cover standard of 70% <br />cover. This amount of cover should be sufficient to <br />and to achieve the capability of the replaced plant <br />-8- <br />