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UTILITY OF OBSERVED LEVELS OF COVER ACHIEVED IN <br /> REVEGETATION TO DATE AT COAL BASIN RELATIVE TO APPROPRIATE <br /> PERFORMANCE STANDARDS <br /> In the permit documents, MCR agreed to establish and monitor a series of test <br /> plots on steep slopes in order to arrive at a reasonable performance standard <br /> for steep slope sites. Those plots were last monitored before MCR left the site <br /> in 1989. As discussed above, the results that year showed an avaerage <br /> percent vegetation cover of 26.6 percent. The quantitative data collected by <br /> Dan Mathews of DMG in Oct. 1998, showed, as discussed above, vegetation <br /> cover in the range of 20 to 40 percent. These data were collected from sites <br /> one to three years old. It would appear encouraging that the performance <br /> standard that MCR would have had to achieve, based on test plot results, will <br /> be reachable using the methods employed by DMG in revegetation efforts to <br /> date. The task left to DMG as a result of MCR abandonment and default, that <br /> is, achievement of successful revegetation in conformance with permit- <br /> mandated standards, appears feasible. <br /> COMMENTS ON 15 JULY 1998 LETTER FROM GREG LEWICKI &ASSOCIATES <br /> The following are comments regarding the numbered points set forth in the <br /> letter of 15 July 1998 from Greg Lewicki & Associates (GLA) regarding an <br /> evaluation that Mr. Lewicki had made of revegetation at Coal Basin. Only those <br /> that I have some basis for comment are included. <br /> 11 <br />