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<br /> <br />III. COMMENTS-COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments in Section IV describe any enforcement actions <br />taken during the inspection and the facts or evidence supporting the enforcement action. <br />Sylvester Gulch drainage, but no part of the Sylvester Gulch channel is proposed as <br />part of the access road (Rule 4,03.2(2)(b)). Sylvester Gulch has been classified as an <br />ephemeral stream on page 2.04-55 of the C-80-007 Permit Application Package and <br />is indicated as an intermittent stream on the Somerset quadrangle. <br />No significant flaw with the proposed alignment was noted by the Division, but <br />compliance with the Rules would be a challenge. The overall grade of the proposed <br />road approaches 10% (overall grade limitation of rule 4.03.2(3)(a)(i)) and there is a <br />110-foot segment of 14.5% (pitch) grade (see the pitch grade limitations of Rule <br />4.03.2(3)(a)(iii)). The alignment is in close proximity to the Sylvester Gulch channel. <br />Design and construction would require care to prevent erosion, siltation and pollution <br />of water (Rule 4.03.2(1)(a)), and additional contributions of suspended solids to <br />streamflow (Rule 4,03.2(1)(b)). Close proximity to the drainage channel will likely limit <br />the use, or require mitigation design of, outslope road profiles (as proposed in the <br />geotechnical report) and dips and undulations (Rule 4.03.2(4)(c)). Mr. Barbe advised <br />that the use of outslope road profiles, and no cut slope ditch designs, were not, <br />based on experience, current MCC preferred design options. A recommendation of <br />the geotechnical report to dispense with toe-of-cut-slope ditches is not in <br />compliance with Rule 4.03.2(4)(c), and would, without mitigation design, preclude <br />the use of sediment traps and other measures of Rule 4.03.2(4)(b)(ii). Vertical and <br />horizontal alignments appear to be in compliance with Rule 4.04,2(3)(a) and (b). <br />Proposed single-lane traffic with turnouts should assist in minimizing disturbance <br />associated with road cuts and embankment fills. Protection of salvaged topsoil (Rule <br />4.03.2(3)(e)(xi)) and materials will require careful selection of storage areas (Rule <br />4.06.3 (an extract of this rule is not provided below as it is not site-specific to the <br />project), <br />Mr. March advised that the US Forest Service could hardly accept the proposed <br />location (due to riparian habitat, unstable slopes, ground water), and suggested that <br />alternatives be considered. One alternative suggested by Mr. March was to locate <br />the road on west and south facing slopes, well above the riparian areas of Sylvester <br />Creek. Other routes and use of other existing roads were other alternatives discussed. <br />Mr. Walker responded to questions that the suggestions appeared appropriate for <br />consideration of alternative alignments by the Division. <br />Four pictures were taken during the reconnaissance. They are included with this <br />report. <br />Copies of this report, the pictures, and the extract (page 2.05-61) from the Permit <br />Application Package for Permit C-81-019 are being provided to MCC and the US <br />Forest Service. <br />C-BO-007, Page _5_ of _11 _ Pages, (date) _4 February 2002 (initials) _BGW <br />