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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 />brief/y describes the problem at each identified area and the proposed mitigative <br />measures. <br />The rill and gully stabilization plan will be implemented by July 1 of each year, or as <br />soon thereafter as ground conditions permit, and completed by November 1 or until <br />weather conditions restrict operations. <br />The referenced Rill and Gully Survey Map (dated 4/29/03) was provided to the Division in a <br />timely manner. The map identified certain permanent drainage channels that required riprap <br />installation or other repairs, and also identified a number of hillslope gullies that were deeper <br />than 1 foot and required revegetation and repair. I inspected the areas of excessive erosion <br />noted on the Rill and Gully Survey Map in July 2003 (see "Stabilization of Rills and Gullies" <br />section of the 8-5-03 DMG inspection report), and also noted certain additional gullied <br />areas (both within permanent drainage channels and hillslope locations) that were in need of <br />repair. On reclaimed hillslopes within 1997 and 1995 reclaimed "A" Pit parcels, I noted <br />that gully erosion had been caused or exacerbated by old contour ditches that had <br />breached. The report specified that in those areas, it would be important that gully repairs <br />include alteration or elimination of the contour ditches that had contributed to the problem. <br />The August 5, 2003 inspection report contained the following advisory: <br />The operator needs to initiate necessary ri// and gu//y repairs promptly, and comp/ete <br />a// necessary repairs, inc/uding work to prevent concentrated flow associated with <br />erosion control ditches, by November 1, 2003. Repairs need to be completed within <br />al/ locations identified on the 2003 Ri// and Gu//y Survey map, the additions/ areas <br />described in this report and any additions/ areas of excessive erosion on rec/aimed <br />areas that may have been missed in the origins/ survey and not observed during this <br />inspection. <br />Based on observations made during this inspection on November 18 through November 20, <br />required rill and gully repairs were minimally and unsatisfactorily addressed. Permanent <br />drainage channels in the "D" Pit area within the 005E-1 drainage and 005 Drainage below <br />the "Duck Pond" stock pond impoundment appear to have been properly graded and <br />riprapped. Some grading and seeding had been completed along the permanent drainage <br />channel on the southern perimeter of the "A" Pit reclamation area, and several of the <br />hillslope gullies in this parcel had been partially graded and seeded. However, additional <br />work is necessary to fully repair the hillslope gullies that were partially repaired. Further, <br />several of the hillslope gullies within the 1997 parcel were not repaired, and the old contour <br />ditches that had breached had not been altered or eliminated. An eroded segment of <br />permanent channel that passes to the south of a small island of undisturbed shrub habitat <br />had been marked for repair on the Rill and Gully Map, but no repairs were evident. No <br />efforts had been made to repair various other gullied areas addressed in the August <br />inspection report. These areas include the hillslope gullies and old contour ditches in the <br />1995 "A" Pit reclamation, hillslope gullies in the 1996 reclamation parcel east of the <br />Ridgeline Access Road (just south of Topsoil Pile GG), hillslope and drainage channel gullies <br />