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Stipulation No. 4 found on page 32 of the September 28, 1982 MLRD Findings Document. <br />STIPULATION NOA <br />If in the future, on-site inspection by the Division or information collected by Colowyo <br />indicate that the suspension of the mulching requirement is detrimental to vegetation <br />establishment or contributes to excessive erosion, mulching will be resumed." <br />Colowyo has intensively monitored the revegetation every year since 1983 and has reported <br />the data to the Division in its Annual Reports. <br />The data collected, as well as our observations in the field, indicate that, as expected, no <br />adverse conditions can be attributed to not mulching. Vegetation has established as expected <br />and there is no evidence of erosion directly attributed to the lack of mulch. <br />The techniques currently utilized by Colowyo to control erosion on these unmulched slopes <br />will continue to be implemented. It is generally recognized that it is the broken surface, <br />contour furrows and drainage benches that contribute to erosion control rather than mulch. It <br />is generally accepted by the local mines in the region that early mulching was completed <br />because of a regulatory requirement rather than any ecological benefit towards successful <br />reclamation. <br />Colowyo recognizes that initial vegetation establishment will continually be monitored <br />through the "monitoring plan" and field inspection by both the Division and Colowyo <br />personnel will continue. If it appears that the suspension of the mulching requirement is <br />detrimental to vegetation establishment or contributes to excessive erosion, mulching will be <br />resumed. Similarly, if site-specific circumstances are encountered where mulching would be <br />a useful metric, it will be reinstated for such circumstances. An example of such a <br />circumstance might be steep slope revegetation in native drainages above sediment traps <br />where vegetation was removed, but otherwise the surface was undisturbed. <br />Given the more extensive south-facing aspects of the South Taylor area and the lack of <br />aggressive non-native grasses in the seed mix, Colowyo is in agreement with CDRMS that <br />the potential for erosion is increased in these areas and additional attention is warranted. <br />However, it is Colowyo's continued position to investigate the efficacy of mechanical <br />measures (e.g., chisel plowing or discing on the contour, contour furrowing, etc.) before <br />reinstating an expensive mulching program. If a mulching program is warranted, there <br />should be adequate research in the literature to suggest the most appropriate procedure to be <br />utilized at Colowyo. <br />Irrigation <br />No irrigation is planned for areas to be seeded or mulched. <br />Pest and Disease Control <br />Noxious plants, as defined in Section 1.04, will be managed in accordance with the following <br />section - "Weed Management Plan". If insects become a problem to the point where they <br />endanger the successful establishment of the seeded vegetation on the reclaimed area, they <br />will also be controlled using methods suggested by the Colorado State University Extension <br />2.05-60 Revision Date: 3/14/08 <br />Revision No.: TR-72