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MEMO to David Buckner <br /> February 19, 1999- Vegetation Comments/Coal Basin <br /> Page 2 <br /> Reports", which you are addressing. It would also be helpful for you to particularly address <br /> the potential for success of the revegetation effort undertaken at Mine 4 in 1997. <br /> Savage mentions in his report that, despite the test plots established at Mine 4 by Mid- <br /> Continent, the potential for successful revegetation of Mine 4 is "very low". Please address <br /> Savage's report, including whether his July 15, 1998 site visit was timely for the purpose of <br /> evaluating fall 1997 reve-etation efforts. Generally, it would be helpful if you could provide <br /> a more detailed rebuttal of the "Savage Report". <br /> 5) Please provide the basis for your report; e.g.: it is based upon your site visit(s), review of <br /> pertinent portions of the permit, review of the "Lewicki and Savage Reports", your <br /> knowledge of the Coal statute and regulations, other pertinent information, etc. <br /> 6) In my review of the Lewicki report, I noticed what I believe are inaccurate statements and <br /> assumptions. The following statements are,meant to clarify comments made in Mr. Lewicki's <br /> report ("Proposed DMG Revegetation on 49 Acres of Mine Downslopes and Road Cut/Fill <br /> slopes" (sic), July 15, 1998). The comments below correspond to the numbered paragraphs <br /> in the Lewicki report. Please evaluate these clarifications, and modify your responses to the <br /> Lewicki report, as appropriate or necessary. <br /> Comment 1 - The price bid to accomplish the North Basin Steep Slope Revegetation Project <br /> will vary between approximately$2,500 and$3,500 per acre, dependent upon which, if any, <br /> of the additive alternates is selected for installation. <br /> Comment 2 - kegarding similarities to Storm King Mountain revegetation; at the meeting to <br /> which Mr. Lewicki refers, the Division mentioned that the BLM found seeding via helicopter <br /> an economic alternative to more conventional means at steep and remote areas. Aerial <br /> seeding is an option for the North Basin Steep Slope Revegetation Project contractor. No <br /> other similarities between the Divisions project and the Storm King revegetation effort are <br /> represented to exist by the Division. <br /> Comment 2 - Soil creep on the steep mine bench outslopes was hypothesized by a <br /> Mid -Continent contractor to be a possible cause for failure of vegetation at the base of one of <br /> Mid-Continent's test plots. The Division is not aware of any measurement of soil creep in <br /> Coal Basin, and is not aware of any study, which documents soil creep to be a factor in <br /> causing vegetation failures in Coal Basin. <br /> Comment 3 - Regarding revegetation of outcrops, these areas are excluded from revegetation <br /> in the context of the North Basin Steep Slope Revegetation Project. <br /> Comment 6- Post permit impacts and crustal formation theories aside, the Division believes <br /> that Mid-Continent has an obligation under the permit to revegetate the mine bench <br /> outslopes. <br />