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treatments would alter the resulting growth of the designed mixture thereby loosing the value <br />of the mixture. Mulches and fertilizers also would destabilize the developmental pathways <br />-~ currently occurring on the site. The results would be unpredictable. <br />If mulch is used on the Lower Zone, about 50 pounds per acre of nitrogen fertilizer <br />(ammonium nitrate) needs to be added or nitrogen deficiency is likely to develop in the <br />vegetation. Hydromulch is not recommend for use on this site except on north facing slopes. <br />PERMIT ALTERATION <br />This plan has been designed to consider, as much as possible, the existing permitted <br />plan. Although the full extent of the quarrying did not take place, the fundamental idea <br />presented in that plan was implemented. This plan basically adapts the existing plan to the <br />existing condition. The primary change in the plan is the revegetation plan. The original plan <br />did not anticipate a long period of inactivity during which extensive natural invasion would <br />occur. Although the original revegetation plan could still be carried out,, that plan would <br />largely eliminate the extensive natural growth that has occurred. The competitiveness of <br />Smooth Brome, a major ingredient in the original plan, would not only crowd out most of the <br />natives, but would also make it difficult for the invading trees and shrubs to develop. It does <br />not seem sensible to short circuit that process because what is developing is far better than <br />what would have been created by the original plan. Much of this site has the opportunity to <br />develop a fairly natural appearing vegetation cover, although full blending with surrounding <br />areas might take a century or more to complete. The revegetation plan proposed here simply <br />augments that growth with less competitive species that should be able to fill the gaps without <br />significantly harming what is there. This should allow the natural processes of successional <br />development to occur. <br />Earthwork is kept to a minimum and is intended simply to repair the trouble spots and <br />make the lands that have not undergone as much revegetation capable of supporting good <br />growth. This is not really a change in the reclamation plan, but is simply an adaptation of the <br />existing plan to existing conditions. <br />For these reasons, the first approach to permit alteration should be through a technical <br />revision. An argument might be made that this is an amendment because the full mining extent <br />was not completed. But, in my opinion, that argument does not carry much weight because the <br />mining went far enough to produce a close approximation of what would have been produced <br />if the full mining had been completed. However, by definition an amendment is a significant <br />change in the reclamation plan in the opinion of the Board. The MLRB might think <br />differently, but I am confident that an argument for technical revision is supportable. <br />f <br />Deer Creek Quarry Rehabilitation June 1994 Page 13 <br />