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The Division would prefer, where possible, for operators of surface <br />mines to use live handled topsoil as opposed to stockpiling it. <br />This recommendation is acceptable. <br />5. No seeding of areas receiving live handled topsoil <br />Kerr Recommendation: <br />Areas receiving Live handled topsoil should not be <br />artificially seeded to assure that the native plants become <br />established. <br />As this issue is otherwise not addressed in Appendix A, the <br />Division awaits further discussion of this issue. The Division has <br />typically required areas receiving live handled topsoil to be <br />mulched and seeded. One exception is Eckman Park where certain <br />areas were neither mulched nor seeded. However, sufficient data <br />has not yet been submitted in order to determine whether this has <br />proven successful. <br />6. Mulching and litter effect on shrub density <br />Kerr Recommendation: <br />Due to the negative influence of mulching and litter on shrub <br />reestablishment, all areas seeded to the perennial mixture <br />and where shrub reestablishment is a goal should not be <br />mulched. Mulching can still be used for critical area <br />stabilization where erosion is a potential problem. <br />The affect of mulching was never discussed in Appendix A, and the <br />only proof showing litter to be detrimental is that an r of -0.0983 <br />was found between litter and big sagebrush density. This is much <br />too low of a correlation coefficient to be used as proof, even if <br />the data and analysis were otherwise acceptable. The fact that a <br />correlation coefficient of 0.1216 was found between bare around and <br />total shrub density also provides no proof. This has not been <br />shown to be an acceptable proposal. <br />7. Invasion of native plants <br />Kerr Recommendation: <br />The invasion of native plants should be encouraged as a <br />primary means of influencing reveoetation success. This can <br />be accomplished by allowing weeds to crow according to their <br />normal life cycle and by encouraging the deposition of native <br />windblown seeds on reclaimed areas. This can be encoura_ed <br />by lea vi no a roughened seedbed, ripping and constructing <br />contour furrows (whenever possible Ciaoonal to the direction <br />of the prevailing winds), and through the utilization of <br />living and artificial snow fences by leaving unseeded strips <br />between passes with the drill. <br />-~- <br />