1985-10-21_GENERAL DOCUMENTS - C1981017 (2)

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Adft Mk Mid-Continent had complied with the requirement of 4.15.3 (1) in making every effort and preparation to seed the tunnel ponds during the normal period for favorable planting, namely in October and November. Natural conditions interfered, and the failure to seed during 1984 was beyond the control, and was not the fault, of Mid-Continent. Mid-Continent further believes that the requirement of 4 .13 for revegetation "as contemporaneously as practicable with mining operations" requires of us that seeding be done after, not before, the necessary repairs to the impoundment structures. It is not practicable, after all, to seed an embankment before digging it up. PERMIT Chapter V, Reclamation Plan. Section G, Revegetation Plan. The company will continue each year, in late fall, to plant various trees, shrubs and grasses to stabilize disturbed areas, control erosion and improve the aesthetics of Coal Basin. Appendix II-B-5. Rock Tunnel Project The following grasses and shrubs would be used for revegetation of all disturbed areas, including the refuse pile. The best time for planting in this area is late fall: October, November. Mid-Continent has been mining in the Coal Basin for nearly 30 years, and has had an active seed and planting program for nearly a decade. Our experience has strongly indicated that seeding in the late fall allows the greatest probability of success. Planting during the spring and early summer subjects the new vegetation to conditions which, essentially, burn it up, as a result of long dry periods, warm temperatures and high intensity sunlight (due to the high altitudes) . Planting during the late summer (August and September) has proven infeasible as well because the seeds tend to germinate in late summer, then freeze due to the cold night temperatures of October. Vegetation begun in the late summer is not likely to survive the winter. Accordingly, it has been Mid-Continent's longstanding practice to seed during October and November, as we have indicated repeatedly in the permit application which was reviewed and approved by both MLRD and the OSM. Neither regulatory authority has ever before indicated dissatisfaction with that practice, and Mid-Continent did not and does not see any reason to alter our schedule for seeding.