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~. ~, <br />a. Re-establishment. Castle merely promises to plant and not <br />to reestablish trees. Even in its amended permit application, it agrees <br />to "reestablish" trees for three growing seasons. The standard f~~r <br />corrective action ought to be restoration and not reclamation. C~istle <br />intends to do even less than reclamation in its CAP. <br />b. Location. Castle's CAP fails to identify where the 1:rees <br />will be reestablished. Does the CAP, for example, require Castle to <br />establish trees in the impoundment area at the base of Area #1? <br />c. Size. Castle proposes replacing 6' to 18' trees with stems <br />probably less than one foot in height. Further consideration should be <br />given to restoring the disturbed areas by planting trees of much larger <br />size. The distrubed areas are north facing and have, before the <br />disturbances, accommodated good tree growth. <br />d. Polyacrylamide. Tree growth is, apparently, facilitated by <br />including moisture-retaining polyacrylamide with the planting. Ca~>tle <br />does not promise to use polyacrylamide but merely to consider usin~.l it. <br />the promise should be definite. <br />4. Culvert HR-6. Castle proposes the installation of culverl: HR-6 <br />which will funnel waters onto Cedar Heights Drive below. Because There <br />is no culvert in Cedar Heights Drive to handle this flow, the <br />installation of culvert HR-6 will cause waters to flow along the side of <br />Cedar Heights Drive and erode it. <br />5. Seepage Collars. Even though Castle indicates on page 9 of its <br />CAP that anti-seep collars should be installed on culverts exceeding 100 <br />feet in length, it does not propose installing a seepage 'collar on <br />culvert HR-3 which i5 130' long. <br />6. Additional Tree Destruction. While stabilizing Area 1, Castle, ~ <br />apparently, plans to grade areas 15' feet beyond the present landsliide. <br />This expansive grading will destroy additional established and <br />significant vegetation. The destruction of these trees must cease. <br />7. Culvert Exits. There is inadequate protection at the exit of <br />the culverts. Protection should extend down the slopes. This is <br />especially important in Area 4 where, apparently, there is no <br />well-defined drainage area. <br />S. Rip-Rap Channel. Rip-rap is needed at the edge of Area 1 to <br />protect the proposed new stream channel from erosion. <br />9. Desiltation Pond. <br />a. Location. By proposing the desiltation pond in the <br />designated area, Castle is expanding its permit area. Has any attempt <br />been made to locate the desiltation pond within the present permit area? <br />- 2 - <br />