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JUL-27-1998 13:20 ROBERT DELANEY 970 945 2303 P.07 <br /> 1ameliorated is by removing the upper portions of the slope or filling the lower portions to a <br /> milder slope. <br /> 4) It is not clear on what basis was the BFM selected for this area. To my knowledge, it has not <br /> been used in any other reclamation in the State nor has it been mentioned in any previous <br /> documentation or reclamation plan for this site. <br /> 5) It was never contemplated in the reclamation plan that trees would be employed in any final <br /> revegetation of the mines. It is particularly questionable since the tree seedling areas coincide <br /> with areas to be revegetated with the grass/forb mixture, which is conflicting. <br /> 6)Page 14 says that 200 trees per acre for 4 acres are required yet later on at the bottom of the <br /> same page, it is stated that 300 seedling trees are required per acre. Which is correct? <br /> 7) Were three bids obtained for the work at Mine 44 and what costs were the other bids? <br /> 8) It appears that the Division is implementing procedures that were never intended in the <br /> reclamation plan and doing so at costs that are much higher than any previous estimate. <br /> Proposed DMG Revegetation on 49 acres of Mine Downslope-and Road Cut/Fill slopes <br /> 1)Although no actual bids have yet been received for this work, it is safe to say that the cost of <br /> the work will be from $4000 to $8000 per acre. The biggest problem with the work is that the <br /> cost is 2 to 4 times what was considered in the reclamation plan to do work that may not provide <br /> any significant improvement in the vegetative cover. In fact, the slopes may be de-stabilized <br /> from the proposed work. <br /> 2) The proposal outlines the scarification work (Task 3)as digging out benches 8" in width and <br /> 12" in length every 5 feet vertically and 3 feet horizontally. Since the material was downspoiled <br /> when the slopes were created, the material is resting at its angle of repose with virtually no <br /> safety factor. Test plot data also indicate that soil creep is also a severe problem. By cutting <br /> these benches into an already unstable slope, the cut and fill portions of the benches must be <br /> installed at even greater angles making them extremely unstable. See enclosed Sketch 1. The cut <br /> .,and fill sections of the benches must be installed on slopes that are approximately 0.5H:1.OV or <br /> 63.4 degrees. Considering these items and the fact that the area receives considerable snowfall, <br /> it is not likely that the benches will last_ The cutting of the benches themselves may disturb what <br /> little surface stability exists now on the slopes and much more erosion may result. It seems a <br /> very high risk to spend so much money on something that is technically questionable. It was <br /> mentioned at the meeting that similar work was done on Storm King Mountain for revegetation <br /> after the fire. First, the soil on Storm King is true topsoil, not the shales, sands and coal waste <br /> that exist at the Coal Basin slopes. Second, the elevations at Coal Basin are much higher with a <br />