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GLA Comment No. 6 <br /> Response: I disagree with the GLA assertion that the soil crusts should not <br /> be broken prior to seeding. If GLA had sufficient experience, it would realize <br /> that a soil crust prevents broadcast seed from achieving the contact with fine <br /> soil particles necessary for any reasonably high chance of eventual germination. <br /> The soil crust that must be attended to prior to seeding may form overnight <br /> after the surface has been wetted. In no way does the presence of sufficient <br /> soil crusting to deter good seed/soil intermixing comprise evidence of lack of <br /> disturbance for decades or even years. <br /> GLA Comment No. 7 <br /> Response: I disagree that there is any requirement to prove reclaimability of <br /> the steep slopes at Coal Basin. During permitting, if so large a fraction of the <br /> site was determined by MCR or DMG to be "unreclaimable" the permit would <br /> not have been issued. The approved reclamation plan included the stabilization <br /> of the oversteepened fills and cuts that MCR had subsequently been granted <br /> permission to leave in lieu of spending the very substantial money that would <br /> have been required to return Approximate Original Contour. Apparently GLA <br /> (and by implication MCR) believes that despite the grant of this huge economic <br /> benefit, the costs of revegetating the steep slopes they abandoned are <br /> excessive and the spoil from road and work area benches should be allowed to <br /> erode to the bottom of the slope. Besides the blatant conflict with the letter <br /> and intent of applicable state and federal coal mining reclamation law, it is not <br /> clear to me that the construction and environmental costs of placing sufficiently <br /> large catchments below all these slopes would not -be larger and perhaps much <br /> larger than the projected revegetation costs. This basically sounds like the <br /> argument of a coal company prior to the passage of SMCRA of 1977 when the <br /> 17 <br />