1993-09-20_GENERAL DOCUMENTS - C1981017 (2)

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based on the results of the lest plots. No DMG documentation shoivs any consideration of the ,years of test plot evaluations. In 1991, DMG undertook a project funded by federal funds to reclaim a portion of the Coal Basin site which was agreed to be "pre-law." The major component of this project was revegetation; including regrading and covering of coal, the incorporation of soil amendments and fertilizer, and re-seeding and planting of 600 tree seedlings and 9600 shrub cuttings and tublings on a steep bench outslope. The techniques to be employed were experimental, based on work in Europe (Krabacher to Delaney, April 29, 1991). At the conclusion of the project, the DMG project manager recommended the monitoring of the vegetation to assess the potential success. No monitoring was ever conducted by DMG. An assessment of the project by Mr. Savage during the summer of 1998 revealed that less than 10 of the 600 trees planted could be found, none of the erosion control cuttings could be identified on the slope, and the seeding on the flat bench surface was sparse at best. In short, the project was a failure. The cost of this project was nearly $74,000, of which over $39,000 was spent on revegetating less than seven acres. Of that spent on revegetation, approximately $29,000 was spent on steep slope revegetation of less than one acre. Yet DMG subsequently proposed similar measures on other sites at Coal Basin. Perhaps the greatest criticism of DMG is their failure to analyze and assess the potential for success of their changes to the reclamation plan, or the consequences of their actions. Much of the reve�oretation has been acknowledged to be "experimental" by DMG staff (Renner to WeStCott, July 11, 1997 and Renner to Crumpacker, April 26, 1999), even though prior experience has shown the same techniques and measures ineffective, at great cost to MCR. The DMG approach to reclamation at Coal Basin may be best summed up by a quotation from their own staff(contained in document c:\miscmine\cbasin.mix) commenting on the development of a seeding rate for the native seed, "So the seeding rate recommendation is pretty much a ball park estimate based on assumptions built on assumptions." Selected Examples of Problems with DMG Reclamation at Coal Basin 1) High Costs - When the DMG took over the reclamation of the site in 1994, MCR had an approved contract with K-Berg Construction to re-topsoil the Sutey Pile for $35,000 or $0.80 per cubic yard. The contractor had already moved his equipment to the site to begin the work. DMG later completed the work with their lowest bidder at a cost of $2.04 per cubic yard not including $10,000 mobilization costs. K-Berg's mobilization was included. This is an exact comparison for precisely the same work at the same time. See Exhibit 2. Also, this is one example of many similar cases. 2) Poor Planning - After the DMG had already reclaimed the lengthy road surfaces to some mines, they later went for bid to conduct steep slope reclamation work at these same mine areas. (North Basin Bid). DMG planned for mulch to be brought to the steep slope areas by 4-wheel ATV (a few bales at a time) so as not to disturb the existing road reclamation. Normal mulch cost per acre: $450. Anticipated DMG Cost: S1722 per acre. Also, it is most unlikely that the mulch will ever remain on the slopes after one winter. 4