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Letter to Joseph de Raismes 10 Mav 3. 1995 the lightly ripped furrows would tend to bury the seecls too deeply. This problem was reevaluated during the Division's April 28, 1995 inspection, when the configuration and disposition of t:he ripped and seeded site could be observed. It was decided that the operator would "harrow" the entire site by dragging a pipe or other such implement behind a tractor or small dozer. This will smooth the reclaimed surface, and provide greatly improved seed-to-soil contact. It should also be noted that a less efficient.seed-to-soil contact when broadcast seeding as compared to dri:Ll-seeding is precisely the reason why seeding rates are ~9oubled when broadcasting, and is the reason for the high pound per acre seeding rate proposed for the Jenkins Site. Your statement that "the site may never return to rangeland" is also disconcerting, in that the Colorado Mined Land Reclamation Act specifies that the site be returned to a beneficial use, and the beneficial use specified for the Jenkins Site is rangeland. Please be assured that if the spring 1995 seeding is not successful in meeting this requirement, additional reclamation measures will be implementE;d until the performance standards of the law are achieved. 12. In concern item number l0 of your April 21, 1995 letter, you raise the issue of a conflict of interest on the part of Bradford Janes, consultant to the operator, and cite the change in Mr. Janes stance on the need for mulch to reclaim the site. It is not for the Division to decide whether Mr. Janes has a conflict of interest or not, and the allegation made in this regard should be taken up with Mr. Janes if you choose to do so. The Division doer not believe that the issue of conflict of interest is germane to bringing the site into compliance with the Mined Land Reclamation Act and the Mineral Rules and Regulations. When Mr. Janes recommended mulch for this site in 1986, it was assumed that the operator would be replacing a screened plant growth medium, into which a straw or hay mulch could be crimped. Since the plant growth medium available at the site is very rocky, crimping would be largely ineffective, and most of the mulch that may be applied would be blown of'f the site by . only moderate winds. In order to compensate for the lack of mulch, the operator has lightly ripped the entire area to bra seeded, and has incorporated a cover, or nurse crop into the seed mix. This is a strategy that the Division considers prudent. Also included in item number 10 of your list of concerns is the disingenuous statement that: There is no reasonable way that a mining operator who has already demonstrated disregard for the terms cf the mining permit and has exceeded the allowable area for major disturbance by a factor of 700 can undertake and complete satisfactory reclamation and meet the long-term nE:eds of public Open Space.