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FEB-02-99 10 :28 AM ESCO-ASSOCIATES 303 499 4276 P. 04 <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 /> GLA Comment No. 2 <br /> Response: Regarding the use of straw mulch, it is one of the most economical <br /> means of addressing the need for mulch. If the point of the objection to <br /> methods of revegetation at Coal Basin is cost, questioning the use of perhaps <br /> the cheapest material available seems illogical. It is true that straw is moved <br /> by wind and that under ideal conditions, it is desirable to hold it down by some <br /> means. However, the slopes involved on much of the Coal Basin site are too <br /> steep for the usual crimping equipment to operate. The effectiveness of straw <br /> on the steep slopes at the Coal Basin site will be limited to locations where the <br /> straw lodges and resists the winds. Under ideal circumstances, applied mulch <br /> would remain evenly in place across the entire revegetation area. However, the <br /> windy conditions at high attitude would make this difficult to achieve in any case, <br /> and the steepness and inaccessibility of the slopes involved at Coal Basin make <br /> it impossible to apply materials or use equipment that might reduce the <br /> amount of wind redistribution of straw. Despite the loss of much of the straw <br /> applied, some small benefit accrues, and contributes to the establishment of <br /> vegetation. <br /> 4 <br />