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inexpensive mulch may provide to the ultimate success of at least some plants is <br /> important. An alternative to achieve more lasting and uniform mulch cover that was <br /> explored by DMG was the use of bonded fiber matrix which was critcized by GLA in the <br /> Mine#4 Downslope Comment No. 4. <br /> GLA Comment No. 6 <br /> Response: I disagree with the GLA assertion that the soil crusts should not be roekn <br /> prior to seeding. If GLA had sufficient experience, it would realize that a soil crust <br /> prevents broadcast seed from achieving the contact with fine soil particles necessary <br /> for any reasonably high chance of eventual germination. The soil crust that must be <br /> attended to prior to seeding may form overnight after the surface has been wetted. In <br /> no way does the presence of sufficient soil crusting to deter good seed/soil intermixing <br /> comprise evidence of lack of disturbance for decades or even years. <br /> GLA Comment No. 7 <br /> Response: I disagree that there is any requirement to prove reclaimability of the steep <br /> slopes at Coal Basin. During permitting, if so large a fraction of the site was <br /> determined by MCR or DMG to be "unreclaimable" the permit would not have been <br /> issued. The approved reclamation plan included the stabilization of the oversteepened <br /> fills and cuts that MCR had subsequently been granted permission to leave in lieu of <br /> spending the very substantial money that would have been required to return <br /> Approximate Original Contour. Apparently GLA (and by implication MCR) believes that <br /> despite the(grant of this huge economic benefit, the costs of revegetating the steep <br /> slopes the e#t abandon re dxcessive and the spoil from road and work <br /> -- - - n <br /> area benches should be allowed to erode to the bottom of the slope. Besides the <br /> blatant conflict with the letter and intent of applicable state and federal coal mining <br /> reclamation law, it is not clear to me that the construction and environmental costs of <br /> placing sufficiently large catchments below all these slopes would not be larger and <br /> perhaps much larger than the projected revegetation costs. This basically sounds like <br /> the argument of a coal company prior to the passage of SMCRA of 1977 when the <br /> assertion of economic hardship allowed virtually no reclamation of coal mine <br /> disturbances to pass as standard operating procedure for so many years. <br /> 13 <br />