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05-10-04 12:05PM FROM-DMG CRAND JUNCTION FIELD OFFICE 0T0 241 1516 T-O6B P.D05/005 F-558 <br />had snow cover from 3 to 12 inches deep at the lime the NOV was issued, and there was <br />continuous snow cover until spring melt in early to mid April. It was in recognition of the <br />fact that initiation of work prior to suitable soil conditions would be impracticable, <br />ineffect(ve, and would cause more environmental harm, that the init(al extension to May 19, <br />2004 was granted. <br />1 am recommending a further extension of. the abatement deadline for the following reasons: <br />1) Based an my site inspection conducted April 27 through April 29, I believe that <br />hiNslopa rill and gully abatement repairs had been diligently initiated and <br />implemented, as soon as conditions allowed. Ground conditions ware still too wet <br />for access by wheeled vehicles, but south and west facing slope locations had <br />within the past week dried sufficiently for access by small dozer, and significant' <br />work had been accomplished. The operator had rented a wide track D-6 dozer for <br />this task. Many of the old breached contour ditches in upper portions of the "A° <br />pit, which had contributed to hillslope erosion, had been eliminated as specified in <br />the NOV. <br />2) North facing slope and valley bottom areas were still too muddy for safe <br />equipment access on April 27 through April 29, and there was additional <br />precipitation (n the area on the evening of April 29 and on April 30. Given the <br />ground conditions I observed in late April, it is obvious that the operator would have <br />had a very limited period of time between the onset of favorable grourid conditions <br />(probably first or second week of May, depending on area) and the May 79 <br />abatement deadline. It is not reasonable to expect that the extensive repair work <br />associated with multiple hillslope gullies and permanent channel segments in <br />numerous locations could have been completed within the brief period of suitable <br />ground conditions (two weeks or less in many locations). <br />Now that the field season is underway, with ground conditions suitable for work in all of the <br />areas subject to the NOV, I believe a period of 30 days should be sufficient to allow for the <br />completion of work necessary to abate the NOV. As such, my recommendation is that the <br />NOV extension be granted for a period of 30 days (to June 18, 2004). <br />