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Given the undeniable need for doing whatever it takes to replace protective <br /> vegetational cover on the abandoned mine disturbance, especially on the steep sites, it <br /> would be my opinion that DMG has taken a very modest approach to the task. MCR <br /> would have one believe that the costs associated are outrageously high. If this were a <br /> mine in the flatlands on the eastern plains of Colorado, the Coal Basin reclamation <br /> costs seem very high. Situated as it is, at high altitude on extremely steep slopes, the <br /> Coal Basin site is probably the most difficult coal mine disturbance in Colorado and <br /> among the top few in the western U.S. The costs for the reclamation of this <br /> disturbance would be on the very high side in any case, but given its abandonment in <br /> an unregraded state the costs to actually achieve reclamation will necessarily be high. <br /> They could be higher. Under a completely reasonable rationale, the approach to <br /> revegetation of the steep slopes could involve the propagation of nursery stock <br /> followed byA placement by hand with extra protection in the form of anchored fabric <br /> mulch. This might easily raise the costs by 5x to 10x. And, of course, it would have <br /> also been completely reasonable (and consistent) for this coal mine to be required to <br /> return approximate original contours ed to do under <br /> ' federal la +- This would have increased the cost of reclamation immensely. <br /> i� <br /> UTILITY OF OBSERVED LEVELS OF COVER ACHIEVED IN REVEGETATION TO <br /> DATE AT COAL BASIN RELATIVE TO APPROPRIATE PERFORMANCE <br /> STANDARDS <br /> In the permit documents, MCR agreed to establish and monitor a series of test plots on <br /> steep slopes in order to arrive at a reasonable performance standard for steep slope <br /> sites. Those plots were last monitored before MCR left the site in 1989. As discussed <br /> above, the results that year showed an avaerage percent vegetation cover of 26.6 , X <br /> 1 <br /> percent. The quantitative data collected by Dan Matthews of DMG in Oct. 1998, <br /> showed, as discussed above, vegetation cover in the range of 20 to 40 percent. These <br /> data were collected from sites one to three years old. It would appear encouraging that <br /> the performance standard that MCR would have had to achieve, based on test plot <br /> results, will be reachable using the methods employed by DMG in revegetation efforts <br /> to date. The task left to DMG as a result of MCR abandonment and default, that is, <br /> 8 <br />