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o More detail is required for the Division to evaluate the proposed seed <br />mixes. Seeding rates should be expressed on a per species basis as seeds <br />per square foot and lbs. /acre P.L.S.. Site descriptions (slope, aspect, <br />etc.) and locations (refuse pile, D portal area, etc.) where the particu- <br />lar mix will be seeded should be included. These requirements also apply <br />to seed mixes for topsoil tockpiles and temporary reclamation within the <br />"D" portal area. <br />o It is stated on page V -43 that "..seed will be applied to steep or rough <br />sites by broadcasting." More detail should be provided regarding which <br />slopes would be considered too steep for drill seeding, how seedbed prep- <br />aration and seed coverage will be accomplished, and the particular method <br />of broadcast seeding to be used. Why will south and west facing slopes <br />necessarily be broadcast seeded? Will seedbed roughening take place con- <br />currently with seeding or in a separate operation. Explain how the drill <br />will be equipped to handle fluffy seeded species and those that require <br />minimal soil coverage. More detail should be provided as to when and how <br />the straw mulching operation will be accomplished. Will it be prior to <br />or after seeding? How will hay and straw mulch which is "free of unde- <br />sirable weedy species" be obtained? Will any specific seedbed prepara- <br />tion of mulching techniques be employed to aid in shrub establishment? <br />o Rule 4.15.1 of the Colorado permanent regulatory program requires that <br />the post mining vegetation be predominately native species unless the ap- <br />plicant demonstrates that the introduced species are desirable and neces- <br />sary to achieve the post mine land use or provide temporary site stabili- <br />zation. Three introduced wheatgrasses and Russian wildrye are listed in <br />the proposed seed mixes. Without pounds per acre information, the staff <br />cannot evaluate the predominance of these species. In addition, no <br />justification has been provided for the inclusion of these species, as <br />required by Section 4.15.2 of the Colorado permanent regulatory program. <br />Documentation of the need for the introduced grasses with respect to ero- <br />sion control and postmine land use is required. <br />-14- <br />