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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />Revegetation/Reclamation Success <br />Aspen test plot soils were laid down in the summer of 2003. Fence construction has <br />recently been initiated, and the operator indicates that preparations are under way to ensure <br />that the water tank, water line, and associated facilities will be in place when required in <br />the spring of 2004. Problems associated with native aspen sapling harvest and storage are <br />previously addressed in the narrative regarding NOV CV-2003-015. Certain additional <br />concerns were discussed with the operator during the inspection. Mr. Karo pointed out that <br />the two soil treatments (roto-cleared and non roto-cleared) were separated north/south <br />within the study area rather than east/west as indicated in the site plan. This discrepancy <br />will need to be addressed and amended as appropriate in the revised study plan, Further, <br />given the steep topsoiled slopes immediately east of the plots and the steep road that will <br />be necessary to access the site from the ridgeline road, diversion ditches will be necessary <br />above the plots and below the end of the road to safely divert concentrated flow away from <br />the plot and away from reclaimed slopes below the end of the road. Map Exhibit 22-1A will <br />need to be amended within the revised study plan to depict all facilities, including the <br />temporary light use road and necessary diversion ditches. <br />2003 seeding and seedbed preparation operations are discussed under Topsoil above. <br />Discussion of revegetation success was included in the Division's inspection report issued <br />August 5, 2003. The Division recommended in that report that the operator assess the <br />success of shrub estab/ishment within the concentrated p/anting locations, and consider re- <br />tieatment...in areas... where plantings have substantia//y /ei/ed, and the bond re%ase <br />standard is c%arly not being met. This request is reiterated. More specifically, the Division <br />recommends that the revegetation monitoring to be conducted in the summer of 2004 be <br />focused on evaluation of shrub planting success within the concentrated planting sites. The <br />monitoring report should include recommendations for appropriate re-planting and/or re- <br />seeding, or other appropriate remedial treatment. <br />The east facing upper valley landform that will be created upon completion of regrading of <br />the "bathtub" pit on the ridgeline would appear to a promising location for the establishment <br />of tall shrub species and possibly aspen, given the slope exposures and potential for snow <br />accumulation. Topsoil replacement and revegetation maps indicate that a thick soil <br />replacement area and associated tall shrub/aspen planting site is proposed for this general <br />location. The current revegetation plan does not specifically require aspen planting in such <br />sites, pending results of the aspen irrigation study. However, it is recommended that the <br />operator consider including some aspen planting in such sites that may be conducive to <br />their survival. The "mother plant" approach as described in the permit for tall shrub species <br />should be considered, possibly using native harvest aspen saplings (a low number of <br />"mother plant" saplings would be requiredl. If live handle topsoil from aspen or tall shrub <br />habitat is available in the summer/fall of 2004, it is recommended that priority be given to <br />10 <br />