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ameliorated 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 B3FM 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 #4 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 Reveaetation on 49 acres of Mine Downslopes 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:1.0V 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 />