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• . page 3 Oct. 6, 1983 Peter O'Connor Chieftain Nine The soil tests also show that there are no especially adverse materials in the spoil or spoil soil mixtures already occurring on the mine and this material can be used effectively on the pit bottom xhere development is more rapid and moisture not such a concern. It needs to be pointed out, also, that the placement of "4 to 5 inches" os soil on a slope is logistically very difficult, The kind of equipment used in topsoil salvage and redistribution is not that accurate. On slopes it is hard to even achieve a t 2 inch accuracy. We have to disagree with your suggestion of changing the plan. The plan was conceived on some sound ecological judgement and altering it, we feel, would cause difficulties 1n revegetation, EXHIBIT E - RECLAMATION PLAN. ITEM 2; We completely disagree with your proposed seed mixture for several reasons. First, our plan calls for revegetating both soil and spoil or spoiljsoil mixtures, and as already stated we do not intend to change that for good reasons. Second, your mixture calls for the use of two species, in particular, which are undesirable in several respects. First, Needle- and-Thread (St1pa comata is a species that readily invades disturbed areas, is already there, and will undoubtedly carryover in the soil in more than sufficient quantities. Also this species is rarely planted because it has undesirable characteristics in range land. It can cause an irritation in the mouths of domestic stock. As a result, it is virtually impossible to obtain and what is available is horribly expensive. Furthermore, the species is primarily adapted to more sandy soils and does not do well in clays. In our opinion, its use on this site is clearly inappropriate. Arizona Fescue, on the other hand, is a very useful species Sn range lands, grows on a wide variety of soils, but prefers well drained sites and soils, and is very drought resistant. Unfortunately, it also exhibits great ecotypic variation and acquiring adapted ecotypes is very important. Because of this characteristic it is not used very much except in specific locations and therefore the demand Ss low, availability low, and price very high. According to some seed suppliers, they do not recommend planting the species because of its poor success rate. I recall a number of years ago some of the major loxland permits issued contained revegetation plans that proposed using this species. To the best of my knowledge, this species has been dropped from most of them and other species substituted. In summary, we will not include either of these species in our mixtures for this mine. What you say about winter wheat is generally true. It can be a problem. But it can also be very useful. In revegetating road cuts with 1.5:1 slopes its value in filling that critical gap during the first groxing season xhen the other species are too small to control erosion far exceeds the problems St creates, IF it is used at rates of 4 pounds per acre or less. On areas where the wheat distribution exceeds that rate, due to normal variations in seed distribution xhen broadcasting steep slopes, it does tend to retard some of the other plants. billing keeps this to a minimum if the slopes permit drilling.