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The fact that the slopes above and below road/work benches were even <br /> steeper than the originally steep conditions in no way diminishes the practical <br /> need to have vegetational cover restored to protect them from erosion. In <br /> fact, the opposite is true. Increased steepness makes these slopes more <br /> vulnerable to erosion and the need for protective cover greater. <br /> Given the undeniable need for doing whatever it takes to replace protective <br /> vegetational cover on the abandoned mine disturbance, especially on the steep <br /> sites, it would be my opinion that DMG has taken a very modest approach to <br /> the task. MCR would have one believe that the costs associated are <br /> outrageously high. If this were a mine in the flatlands on the eastern plains of <br /> Colorado, the Coal Basin reclamation costs would seem very high. Situated as <br /> it is, at high altitude on extremely steep slopes, the Coal Basin site is probably <br /> the most difficult coal mine disturbance in Colorado and among the top few in <br /> the western U.S. The costs for the reclamation of this disturbance would be on <br /> the very high side in any case, but given its abandonment in an unregraded <br /> state the costs to actually achieve reclamation will necessarily be high. They <br /> could be higher. Under a completely reasonable rationale, the approach to <br /> revegetation of the steep slopes could involve the propagation of nursery stock <br /> followed by placement by hand with extra protection in the form of anchored <br /> fabric mulch. This might easily raise the costs by 5x to 10x. And, of course, it <br /> would have also been completely reasonable (and consistent) for this coal mine <br /> to be required to return all disturbed areas approximate original contour. This <br /> would have increased the cost of reclamation immensely. <br /> 10 <br />