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FEB-02-99 11 :08 AM ESCO-ASSOCIATES 303 499 4276 P. 01 <br /> General GLA Comments on Revegetation of Mine Downslopes and Road Gut/fill <br /> 8lvpas <br /> GLA Comment No. 1 <br /> Response: IF MCR had not defaulted on its reclamation responsibilities and <br /> was conducting the reclamation themselves, the costs to achieve reclamation <br /> would be very similar. GLA is apparently suggesting that it was never <br /> necessary to conduct revegetation in the first place, that the slopes have <br /> stabilized on their own, and that, as they explicitly state, the process of <br /> revegetation might disrupt this acquired stability. If GLA believes that these <br /> extremely steep slopes are now stable by virtue of having nothing at all done <br /> to them, and with next to no vegetation on them, why is revegetation for <br /> erosion control required anywhere? <br /> GLA Comment No. 2 <br /> Response. As MCR constructed them, the slopes in question are indeed very <br /> steep and close to the angle of repose. It is agreed that they are unstable as <br /> is obvious to anyone who has seen them (and, it may be noted, in direct <br /> contradiction to the apparent GLA implication of the preceding comment). <br /> And, as has been discussed previously, the process of establishing plant growth <br /> on these steep loose debris is most difficult and slow. Because of this difficulty, <br /> any advantage, however slight and however brief its existence may prove <br /> critical to the establishment of plant growth. The advantage rendered by <br /> benches is greater the more extreme the default condition. The fact that <br /> revegetation conditions on Storm King Mt. were more favorable that the Coal <br /> Basin slopes only emphasizes how important these small and temporary <br /> germination/establishment sites may be on a relative scale. Each small <br /> amelioration of the steep slope rigors, even though temporary, contributes <br /> 7 <br />