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n Mr. Afark S. Lo ye -3- October 19, 1982 obviously the site is not particularly dry for that species. The term dry environment is totally relative - the alpine tundra is as physiologically dry as the Sonoran Desert is precipitationally dry. The Arctic Tundra is actually more of a desert than Colorado Springs. In order to avoid such ambiguous terminology, cve suggest that the standard of expectation for revegetation be the natural vegetation growing on adjacent areas. That is precisely the reason why Section 116(1)(f) speaks to the cover of surroundiny vegetation. The law clearly intends to have tl~e natural vegeta- tion as the standard of comparison for revegetation projects that attempt to produce at least a functionally similar vegetation. The surrounding area, so to spea);, is the empirical standardY for an area. Therefore, if a cover comparable to the surrounding vegetation can be produced without mulches (assuming it is composed of more than weeds) within the time frames allowed by the law, there is Little reason to use expensive mulches that might save a year or two in achieving that cover. The benefits derived from the expen- diture are hardly worth the effort. As you may recall, over 40 acres were planted in 1979 at ti7e Christian Pit. On areas where topsoil was not placed and the medium is gravelly, plant cover is quite low. But where topsoil was placed, the vegetation averages bet~~~een 60~ and 90`5 of the natural vegetation cover of surrounding areas. The drill rows are still evident but tillering and reporduction has clearly begun to fill the areas between the drill rows. It must be noted that generally the species planted in 1979 were not good sod-formers and yenerally were not very appropriate for the site. Nevertheless. all of this growth has been achieved totally without the aid of mulches. Gle feel that plant cover should be adequate for bond release in another two to three years (five years total). It is apparent that growti~ on moisture favorable sites (level, north, and east facing slopes) is good without the aid of mulches. The point of mulching south and west facing slopes is to produce environments in the same moisture regime as level areas where moisture is adequate for good growth. In light of the empirical evidence, it does not seem logical that the placement of moderate mulch on level areas and heavy mulci~ on south and west facing slopes will necessarily produce any better results. Such mulching may, in fact, produce a density and cover that is unsupportable in the natural environment. In conclusion, we do not believe that alteration of the existing proposed plan for mulching is logical and cannot be supported with data. As a matter of fact, the evidence we have seems to indicate just the contrary, that is, if proper species are planted in a soil of adequate dept; mulches are a needless luxury and could possibly do harm. The relevancy of soil depth to tl;e subject of mulching involves the primaru function of a mulch, to cool the soil and retain moisture. If a soil has a yi ven water holding capacity, measured in inches of water per inch of soil, and that capacity is a measure of available water then a given de.ptl~ of soil