Laserfiche WebLink
each reclamation task is to be accomplished. Include in your response the specific basis for your <br />answer including the pertinent portions of the permit upon which you rely. <br />ANSWER NO. 13: Objection. The Plan speaks for itself. See, however, reports <br />prepared by Greg Lewicki and Mike Savage regarding the Reclamation Plan. <br />INTERROGATORY NO. 14: State the factual and/or legal basis for the third -party <br />plaintiffs' allegation, pleading, statement, belief, or contention in paragraph 32 of the Amended <br />Third -Party Complaint that steep slope revegetation is experimental and that the 1997 steep slope <br />revegetation has been a failure. Include in your response the specific definitions of <br />"experimental" and "failure" you are using to make this allegation including the degree of <br />vegetation used and the methodology used in making the determination and/or allegation that the <br />vegetation was a failure and your definition of what "success" would be in regard to the steep <br />slope revegetation which is the subject of paragraph 32. <br />ANSWER NO. 14: The consistent failure of all previous efforts by DMG to revegetate <br />outslopes at Mines #5, #3 and #4; the massive slope failure which occurred at Mine #4; the <br />results of the test plots and studies performed through 1991; DMG's own failure to monitor <br />previous efforts. Steve Renner has referred to the efforts as "experimental." See memo from <br />Steve Renner to Peter Westcott, dated July 11, 1997. No such slopes have been successfully <br />revegetated. Success or failure was to be determined by evaluation of test plots which did not <br />occur. See also § 4.15 of DMG regulations. <br />INTERROGATORY NO. 15: Identify each document which was referred to or relied <br />upon to respond to the above Interrogatory no. 14. <br />ANSWER NO. 15: See response to Interrogatory No. 14, above. <br />INTERROGATORY NO. 16: Identify any and all benches and roads which pertain to <br />or are included in your allegations in paragraph 36 of the Amended third -Party Complaint. <br />ANSWER NO. 16: The roads include the roads to mines No. 5 and No. 3 and the No. 5 <br />mine fan road, and roads and benches for Mines 1, 2, 3 and 4. <br />INTERROGATORY NO. 17: State the factual and/or legal basis for the allegations <br />contained in paragraph 37 of the Amended Third -Party Complaint, including, but not limited to, <br />which roads and significant motorized vehicle traffic are included in or pertain to the allegations <br />of this paragraph, the definition of "significant motorized vehicle traffic" used in making this <br />allegation, and the date of the traffic alleged to have occurred over revegetated roads and the <br />acreage affected by this traffic. <br />ANSWER NO. 17: "Significant motorized vehicle traffic" is that amount of traffic <br />which will disturb the revegetated areas to such an extent that it will require re- revegetation. <br />DMG has solicited bids for down slope revegetation at the No. 3 mine and No. 5 mine which will <br />require traveling over the revegetated roads to those mines. DMG has the information to <br />calculate the acreage (i.e. width of roads times length of roads). <br />8 <br />