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use of the optical point frame and he agreed that the method is considerably more strict <br />than their method of estimating cover. <br />d 6) During the reclamation of the site, the yard area was torn up extensively in order to <br />remove foundations and the area was also ripped prior to topsoil placement. See enclosed <br />picture in this section during the actual reclamation. SMC has done everything it could do <br />in preparing the site for reclamation and avoiding compaction problems which could hurt <br />root development. The picture also shows that the coaly yard material is over 2.5 feet <br />thick, which was typical for the entire site. <br />7) At the request of the landowner, the original reclaimed seed mix consisted of timothy, <br />orchardgrass and smooth brome. Summer droughts have severely hurt the timothy and <br />orchardgrass growth and almost every year since 1992, some additional seed from various <br />drought-resistant species has been added almost every fall, with only moderate success. <br />8) SMC has also brought in additional pig manure in some poor spots, and has conducted <br />minor aeration of the site in the first few years after initial reclamation. This has also <br />shown only minor improvement. <br />9) The site was initially seeded in the fall of 1992. In the spring of 1993, the site showed <br />an excellent young cover which was very encouraging. However, the summer and <br />subsequent years have shown a significant decline (or lack of major improvement) since <br />that initial growth. SMC believes this is due to the fact that the site conditions simply <br />cannot support a high vegetation level. Picture 3 of this section shows the site in early <br />May of 1993 and Picture 4 shows the site in July of 1996, more than 4 years later. <br />10) In August of 1994, a vegetation study of the site was conducted by Matt Hayes. The <br />study showed that the vegetation was much lower than the standard. Also, in subsequent <br />years, selected ripping, re-seeding, manure addition and fertilizing has not improved the <br />vegetation to a level that even approaches the standard. <br />11) Soil samples were taken in the summer of 1995 and were sent to the Colorado State <br />University soil lab. The results of these tests are enclosed. The high carbon level in some <br />of the subsoils is the result of the coal in the yard material below the topsoil. <br />12) See enclosed support letters ~2) for a reduction in the standard from Pat Davey from <br />the SCS. The change in 2002 is a minor change to the species diversity standard and is <br />supported in Pat Davey's second letter. <br />d 13) See enclosed support letters for a reduction in the standard from Matt Hayes, the <br />principal vegetation specialist who studied the site and formerly worked for the DMG. <br />4 14) See enclosed support letters (2) from the landowner, Bernard Knott. <br />15) The previous standard was the highest in [he State for any coal mine, and this site is a <br />pre-law site with no topsoil ever salvaged. Many other mines with far better conditions <br />have far lower vegetation standards. <br />TR May 2002 184-13 <br />