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RULE 2 PERMITS <br />have proven highly successful in controlling erosion on slopes as steep as 3h:ly until vegetative cover has <br />been established. <br />The Division's concerns were previously directed at vegetative establishment on the unmulched areas. <br />The Division's initial permit concerns were expressed in the following Stipulation No. 4 found on page 32 <br />of the September 28, 1982 MLRD Findings Document. <br />Stipulation No. 4 <br />If in the future, on-site inspection by the Division or information collected by Colowyo indicate that the <br />suspension of the mulching requirement is detrimental to vegetation establishment or contributes to <br />excessive erosion, mulching will be resumed." <br />Colowyo has intensively monitored the revegetation every year since 1983 and has reported the data to <br />the Division in its Annual Reports. The data collected, as well as our observations in the field, indicate <br />that, as expected, no adverse conditions can be attributed to not mulching. Vegetation has established as <br />expected 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 will continue <br />to be implemented. It is generally recognized that it is the chiseling, contour furrows and drainage <br />benches that contribute to erosion control rather than the mulch. It is generally accepted by the local <br />mines in the region that early mulching was completed because of a regulatory requirement rather than <br />any ecological benefit towards successful reclamation. <br />Colowyo recognizes that initial vegetation establishment will continually be monitored through the <br />"monitoring plan" and field inspection by both the Division and Colowyo personnel will continue. If it <br />appears that the suspension of the mulching requirement is detrimental to vegetation establishment or <br />contributes to excessive erosion, mulching will be resumed. <br />Irrieation <br />No irrigation is planned for areas to be seeded or mulched. Possible watering of transplanted shrubs or <br />seedlings, with supplemental applications during the first two growing seasons, will be the only water <br />used during revegetation. Colowyo watering trucks used for dust control will be used for the <br />supplemental watering. <br />Pest and Disease Control <br />Noxious plants, as defined in Section 1.04, will be controlled using the recommended methodologies of <br />the Colorado State University Extension Service. If insects become a problem to the point where they <br />endanger the successful establishment of the seeded vegetation on the reclaimed area, they will also be <br />controlled using methods suggested by the Colorado State University Extension Service. All herbicides <br />and pesticides utilized will be those that are approved by the appropriate state and federal governmental <br />agencies responsible for the approval and distribution of such agents. <br />Measures for Determining Success of Reveutation <br />The success of revegetation will be determined as explained in subsection 4.15. <br />Rule 2 Permits 2.05-30 Revision Date: 6/23/08 <br />Revision No.: MR-91