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• ~~I II~II~I~~II~~ ~I~ • ~. Environmental Services 37 E Colorado Avenue Denver, CO 80210 (303) 722 - 9 0 6 7 October 25, 1982 Mark Loye Mined Land Reclamation Board Centennial Building Room 423 1313 Sherman St. Denver, C0,80203 RE: Christian Pit, File number 82-155 Additional responses to adequacy concerns Dear Mr. Loye: I have been asked on behalf of Schmidt-Tiago to respond to the remaining items for the Christian Pit amendment. It appears that three items still need some clarification. They are: the questions concerning mulching and bonding for mulching, the action to be taken in the event a significant calcareous layer is encountered in the soil, and the difficulties created by the semantics of the word pond. MULCH AND BONDING FOR MULCH: I can well understand the lack of agreement among your revegetation people regarding the use of mulch in particular situations. Those differences of opinion are well reflected in the literature which certainly does not come to any precise conclusions either. One agronomist says mulch is needed almost everywhere, while another equally well qualified agronomist finds it should be used sparingly. Some authors are convinced that mulhh accelerates establishment; others agree but add a long list of "howevers." It certainly appears to be one of those areas needed more study, It seems to be like the question of fall vs. spring planting - the answer is not all that clear cut. Our original arguments regarding mulching at this site are not intended to be eliminated by this letter. We still believe that mulch is not needed to establish good growth within about 5 years. We feel that the law clearly states that the cover of the surrounding vegetation is the standard for determining completion of revegetation, especially when the S.C.S, survey for the area indicates that what is growing there now is what can be reasonably expected. We still believe the climate is suitable for the establishment of these species without mulch, especially when one considers dormancy factors of native species, the available water holding capacity of the soil, and other factors. We still believe those literature citations which state mulch can cause more problems than it solves have much to their credit. Among the problems are: