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FEB-02-99 10 :38 AM ESCQ-ASSOCIATES 303 499 4276 P. 01 <br /> toward the establishment of mature plants that can withstand the surface <br /> instability and thereby, in aggregate, lend stability to the slope as a whole. <br /> The absence of a major national highway at the base of the Coal Basin slopes <br /> has not been relevant to past or present determinations of the legal <br /> requirements for revegetation of this site. <br /> GLA Comment No. 3 <br /> Response: At some few locations, the exposed rock present is sufficiently <br /> hard to make establishment of plants difficult. If MCR were undertaking the <br /> reclamation of their disturbances, the provisions of the permit would have <br /> necessitated the placement of topsoil in order to achieve revegetation. From a <br /> practical standpoint, many of the road cut sites have the exposed rock <br /> sufficiently weathered and/or have a veneer of colluvium from upsiope so that <br /> at least modest prospects of revegetation are present. <br /> GLA Comment No. 4 <br /> Response: See response to Comment No. 2 in first section. <br /> GLA Comment No. 6 <br /> Response: The soil crust that must be attended to prior to seeding may <br /> form overnight after the surface has been wetted_ In no way does the <br /> presence of sufficient soil crusting to deter good seed/soil intermixing comprise <br /> evidence of lack of disturbance for decades or even years. <br /> GLA Comment No. 7 <br /> Response: The approved reclamation plan included the stabilization of the <br /> oversteepened fills and cuts that MCR had left in lieu of spending the money <br /> 8 <br />