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<br />Mr. Allen Weaver, EFMC 2 C-82-055 <br />The Division's determination of success of the initial seeding may occur after two years <br />following seeding and would be based upon observations such as, but not limited to: <br />` evaluation of the success of vegetation establishment based on the presence and <br />vigor of seeded species; <br />` comparison of vegetative growth on topsoiled areas seeded during the same <br />season as the areas lacking topsoil cover; <br />' comparison of the erosion on the slopes with and without topsoil cover; and <br />' Rules 4.15.7, 4.15.8, and permit section 2.05.4(2)(e) Revegetation. <br />The Division understands that prior to seeding, all backfilled slopes would be "chiseled" on <br />aline perpendicular to the slope. Chiseling the slope along the contour would remove <br />existing gullies, help slow the speed of runoff thereby reducing future erosion and increase <br />soil moisture for revegetation, and reduce compaction. Some gullies may require more <br />extensive repair than can be accomplished with chiseling alone. As per recommendation <br />number 6 of your report, disking in addition to chiseling is desired to prepare the seedbed. <br />The Division has reviewed the seed mix approved in the permit (page 524) and finds the <br />seed mix to be appropriate. in addition to the approved seed mix, the Division suggests <br />transplanting pinyon and juniper seedlings on the slope lacking topsoil cover. Pursuant to <br />Rule 4.15.7(5), transplanting native species within the first five years of any ten year liability <br />period shall not cause the liability period to be re-initiated. <br />Pursuant to recommendation 9 of your report, the Division also recommends drill seeding <br />in lieu of broadcasting. Drill seeding at the same rates approved for broadcasting is also <br />recommended, especially for the slopes lacking topsoil. <br />Sincerely, <br />Cl)~,~~/ <br />Wallace H. Erickson <br />Environmental Protection Intern <br />cc: Dan Hernandez <br />Larry Routten <br />Tony Waldron <br />