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moisture conservation. TCC contends that, under the definition set <br />forth in Rule 1.04(74), regraded spoils intermixed with soil materials <br />satisfies the requirement for mulch set forth in rule 4.15.4. <br />The coarse fragment content of final graded spoils will serve to <br />impede surface runoff, thereby enhancing infiltration and decreasing <br />erosion potential. In a comprehensive review of mulching, Kay (1978) <br />reported that a ground -cover of gravel effectively reduces wind and <br />water erosion. Meyer et al. (1972) found a stone mulch 1 inch deep to <br />provide more effective erosion control than 3,992 lbs. /acre of straw. <br />Negligible weathering of the coarse fragments will occur between final <br />grading and vegetation establishment, as demonstrated in Table 33 <br />Percent Size of Weathered Spoil According to Age. Therefore, the <br />textural properties of the spoils will afford erosion control until a <br />protective plant cover develops. <br />Furthermore, regraded spoils will only remain in a potentially <br />vulnerable condition for a short period of time because many of the <br />introduced species proposed for inclusion in the two perennial seed <br />mixtures exhibit early and rapid phenological development. Laycock <br />(1981) concluded that "germination rates and ease of establishment <br />tend to be higher for introduced species than for native species." <br />Based upon the physical characteristics of the spoils and the <br />intrinsic growth habits of the naturalized introduced species included <br />in the permanent seed mixtures. <br />Twentymile Coal Company hereby requests the Division to suspend the <br />requirement for mulch on the proposed Fish Creek Tipple permit area. <br />The mulching variance requested in this permit application is also <br />founded on the condlusions drawn from a comprehensive literature <br />review and field data collected in the vicinity of the proposed permit <br />2.05 -45 <br />