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t <br />Memo -Cathy Begej - 3 - November 3, 1989 <br />Monitoring Schedule <br />Presently, Kerr is committed to biennial monitoring of revegetated areas. <br />According to this commitment, Kerr would sample reclaimed areas in years 2, 4, <br />6 and 8 after seeding in addition to years 9 and 10 which would be monitored in <br />anticipation of potential bond release. The newly submitted revision calls for a <br />minimum of sampling once every 3 years, or in years 3 and 6 in addition to 9 and <br />10. It is important that operators commit to two monitoring periods prior to the <br />fifth year following seeding. Per Rule 4.15.7(5), the fifth year is the last year <br />that certain revegetation repair practices may be applied without automatically <br />re-initiating the ten year liability period. Thus, the Division strongly <br />recommends that Kerr Coal commit to vegetation sampling of cover and woody plant <br />density in years 2, 4, and 7. <br />Commitment to Reseed Live Topsoiled Area <br />Page 205.4-30 contains a commitment to reseed live topsoiled areas in the <br />".... unlikely event that re-established vegetation communities in those areas <br />... do not meet regulatory success standards, ....". The Division request that <br />Kerr expand the narrative to address when revegetation success will be monitored <br />on live topsoiled areas, what methods will be used when monitoring, and what <br />level of revegetation success Kerr will consider to be acceptable. <br />Field Trials <br />Rule 4.15.6(3) states that the Division may require field trials which, according <br />to Rule 4.15.6(1) may "include tests of various aspects of the plan such as <br />different seed mixes, alternative soil stabilization procedures and variations <br />in seeding or planting times." Kerr Coal's proposals to not seed or mulch areas <br />receiving live handled topsoil warrant testing with relatively large scale field <br />trials. The goals of these trials can be made specific enough that results of a <br />well designed trial can be evaluated within an adequate time frame to be useful to <br />the operator. The effectiveness of using live handled topsoils is not questioned. <br />However, the Division has yet to be convinced that revegetation efforts will not <br />be hampered when mulching and seeding of the perennial seed mix are not employed. <br />Living Snow Fences <br />The use of living snow fences could possibly increase revegetation success as <br />Kerr Coal suggests by increasing snow and native seed deposition. Please clarify <br />the following issues: <br />1. Will living snow fences be seeded on areas receiving live handled topsoil? <br />2. How far apart will the living snow fences be from each other? <br />3. The Division is concerned about the use of tall wheatgrass as a living <br />snow fence species. This species has been found to have poor <br />establishment rates at the mine site and as a result has been deleted <br />from the revised permanent seed mix. Is there another species that would <br />be more suitable that could be substituted for tall wheatgrass? <br />