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The test plots established in 1984 at Mines 1, 4 and 5 were monitored in 1989 by IMS, <br /> Inc. At that time, 5 years after their establishment, vegetation cover ranged from 21 to <br /> 37 percent, and averaged 26.6 percent over all plots (IMS 1989). Although some plots <br /> had been severely damaged by erosional action, the presence of an average of 26 <br /> percent cover is clearly an important deterent to erosion on much of the area that was <br /> reclaimed. I disagree with any claim by MCR or its consultants that this level of <br /> vegetational cover is not worth the effort and expense. <br /> EVALUATION OF AREAS REVEGETATED BY DMG AT COAL BASIN SINCE 1995 <br /> Dan Matthews of DMG reviewed the results of mine closure revegetation efforts <br /> accomplished between 1995 and 1997 on the Coal Basin site during the period of <br /> October 13 to 15, 1998 (DMG letter report of 4 February 1999). His observations <br /> included quantitative data on percent ground cover on many of the sites. His <br /> observations indicate that within the elapsed one to three growing seasons, plant cover <br /> was mostly in the range of 20 to 40 percent, with a few as high as nearly 50 percent <br /> and a few as low as 15 percent. This again clearly demonstrates the feasiblility of <br /> establishing cover on even the steep slopes in Coal Basin. <br /> EVALUATION OF POTENTIAL SUCCESS OF REVEGETATION EFFORTS THAT <br /> HAD BEEN PLANNED FOR 1998, BUT WERE NOT CARRIED OUT. <br /> General <br /> Based on observations of results of 1996 seeding at Mine 1 and adjacent to Road D, I <br /> believe that the prospects for success in establishing the species in the prescribed <br /> seed mix in 1998 work would have been very good, recognizing that along with any <br /> effort to establish plants from seed comes a chance of failure. The chance of failure <br /> that attends any particular reseeding effort in no way relieves the necessity of ultimate Z;e' <br /> successful re-establishment of vegetation on that site, and this site is no different. <br /> Specific <br /> The specific procedures set forth in the bid document for North Basin Steep Slope <br /> Revegetation Project are appropriate to the severity of the site conditions. They <br /> 5 <br />