1999-05-14_GENERAL DOCUMENTS - C1981017

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Specific Comments 1) Please expand the introduction to include items touched on later int eh report, including a general description of the site conditions; that, at least to a certain extent, the steepness of the mine bench outslopes is due to the deposition of overcast materials in these locations; that surficial instability, expressed as erosion, is controllable to a degree by establishment of vegetative cover; that establishment of vegetative cover is feasible, given MCR test plot data, and given Division revegetation demonstrations at various locations; that the need to accomplish revegetation is great, given ecologic considerations, permit obligations and legal requirements, and therefore efforts at revegetating the mine bench outslope and road cut and fill slopes should be undertaken using the best technology and practices applicable to the site and conditions. 2) Please provide a more exhaustive explanation regarding the difficulties of high altitude revegetation, particularly at highly disturbed sites. The discussion should evolve toward the obvious feasibility of achieving a reasonably successful vegetative cover, and that the Divisions' demonstrations show signs of success. 3) The points made in items 1) and 2) above were touched upon in the draft report. Please expand upon those discussions in the body of the repot, again given your experiences and site conditions, as a basis for these conclusions. 4) Where you agree with our revegetation procedures, please clearly state so. When you disagree with either the "Lewicki or Savage Reports", please clearly state so. 5) Please add a statement that your report is based upon your site visit(s), review of pertinent portions of the permit, review of the"Lewicki and Savage Reports", and your knowledge of the Coal statute and regulations, as well as any other pertinent information. 6) Please address the following items in the context of the report: - What techniques, if any, could be incorporated into the steep slope revegetation practices outlined in the"North Basin Steep Slope Revegetation Project" in order to enhance the potential for successfully revegetating steep slopes; - Is the seed mixture and application rate adequate and/or appropriate for the site conditions; - Please provide your thoughts on the Divisions practice of collecting and redistributing seeds from Calamagrostis purpurascens at steep slope areas;: - Given Dan Mathews findings regarding cover and diversity, reflect upon the relative success of the demonstration projects accomplished to date at Mine I and Road D; - Is the Divisions' approach to steep slope aggressive enough. If not, suggest changes in methodology;