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Applicant's Response to Second Adequacy Letter Grand River Park Project, DRMS File M-2006-046 January 2, 2007 Page 6 or equivalent (e.g., manure), to be evenly worked into the plant growth medium by contour plowing. To ensure maximum germination, seed from the specified reclamation mix will be planted by drill seeding or by other mechanical means that scarify the bed and ensure consistent moisture conditions and soil contact. The seeded bed shall be mulched with 2000 lbs./acre of weed-free straw or native grass hay, then crimped. Given a uniform minimum topsoil layer of six inches and this soil amendment program, the reclaimed plant growth medium will meet and exceed all requirements to support the specified post-mining use and associated vegetation. 13. In the Reclamation Plan, the applicant commits to following the recommendations of the NRCS in order to reestablish vegetation on the site. However, on the Reclamation Plan Map the applicant has added a Plant Schedule consisting of several types of trees and shrubs. The Division appreciates the applicant's effort to establish a diverse vegetative cover with the use of trees and shrubs, but please provide a standard for the surviving quantity after five years or upon a future release request. The above comment appears to relate to a new adequacy issue, as the applicant clarified and committed to appropriate NRCS reclamation recommendations related to Comment 13 in the Division's initial adequacy review. The applicant included revised reclamation plans (e.g., Exhibit F) with the September 6, adequacy response, at which time woody vegetation was shown to supplement the planned land cover. Supplemental trees and shrubs are intended to enhance the reclaimed site as a recreational amenity, including the attractiveness of the site for wildlife. The benefits of woody vegetation should not be understated, as such enhancements are directly responsive to review by local Division of Wildlife officials and the recommendations of a consulting biologist; however, these enhancements were not requested by the Division of Reclamation, Mining, and Safety, and the enhancement intent does not dictate any particular percentage cover or survival ratio. No specific survival ratio is requested in the above comment from the Division and no guidance as to an appropriate survival ratio is provided by the Construction Materials Rules. In further conversation with the Division, a 20 percent survival ratio was cited as an appropriate target. It is assumed that this measure would be taken after an appropriate period of time, such as two growing seasons after planting, or upon request for reclamation release. This is not to say that 80 percent woody plant mortality is to be desired or encouraged; rather, some mortality in any planting situation may be expected, and the applicant/operator will therefore purchase warrantied plant materials meeting nursery stock standards to ensure the greatest chances of survival. The applicant commits to live shrub and tree cover somewhere in the range between a stipulated minimum 20 percent of the