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In every instance, sites receiving straw mulch produced from 12 to 13 <br />percent lower seedling survival than did the controls. <br />At the ColoWyo Mine, Herron and Berg (1977) reported considerably <br />lower shrub seedling survivial for mulched plots in their shrub <br />management practice study. Shrub seedling mortality on unmulched <br />plots was 52 percent while plots mulched with 2 tons per acre of <br />alfalfa experienced a shrub mortality rate' of 75 percent. In another <br />study reported by Herron and Berg (1977), percent vegetative cover of <br />seeded herbaceous species on a control plot declined 24 percent from <br />1976 to 1977 while a straw mulched plot underwent a 68 percent <br />reduction in plant cover for the same time period. <br />Data and observations collected on the CYCC mulching plot studies in <br />Lease C -20900 made during the Summer and Fall of 1980 indicate no <br />superiority of mulching either with barley straw or annual grains over <br />direct seeding to perennials. Plant cover was not different and a <br />significant amount of runoff did not occur on mulched or non mulched <br />plots. <br />In summary, these data document that the planting of an annual grain <br />mulch hinders the development of perennial species. The use of an <br />annual grain mulch under these conditions makes it difficult to <br />achieve the plant cover and woody plant density requirements specified <br />under Rule 4.15.8, within the ten year liability period. <br />Consequently, TCC believes that it is desirable, from a revegetation <br />standpoint, to seek a variance from the mulching requirement in <br />connection with this permit application. <br />Conclusion <br />Under Section 4.15.4(5) authority is granted to the Division to <br />"suspend the requirement for mulch if the permittee can demonstrate <br />that alternative procedures will achieve the requirements of 4.15, and <br />do not cause or contribute to air or water pollution ". It is the <br />2.05 -47 <br />