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(b) Rills and gullies which form in areas that have been regraded and. topsoiled and which either (1) disrupt the approved postmining land use or the reestablishment of the vegetative cover, or (2) cause or • contribute to a violation of water quality standards for receiving streams shall be filled, regraded, or otherwise stabilized; topsoil shall be replaced; and the areas shall be reseeded or replanted. Colorado Yampa Coal Company believes not all rills and gullies in excess of 9 inches require immediate repair. In most instances, a rill or a gully greater than 12 inches does not disrupt the approved postmining land use and would not preclude the reestablishment of vegetative cover. Often, active gully formation is of limited temporal and spatial extent and once vegetation becomes well established, the erosion is checked. Furthermore, as is known, the repair of rills and gullies may disrupt more of the surrounding area than the actual area occupied by the dully. This situation is acknowledged by the Division in Rule 4.14.6(1) and in the rill and gully policy. In light of this situation, CYCC believes monitoring of some gullies is the prudent means of providing mitigative measures rather than repair of the • area. Therefore, Colorado Yampa Coal Company intends to incorporate a monitoring program as part of the reclamation plan for rills and gullies. Such rills and gullies designated for monitoring would include those within or down-slope of newly topsoiled and seeded areas. The gullies may be in excess of the 12 inch standard but the density must be less than or equal to one per acre (209 foot centers). If surveys indicate the areas continue to show accelerated erosion, repair work will be initiated. The monitoring period will extend three years and monitoring will be conducted during the annual spring/summer rill and sully survey. Repair work will be initiated at anytime during the three year period, if erosion becomes excessive. The depth standard for remedial repairs of rills and gullies not included in the monitoring plan will be 12 inches. CYCC will continue to repair rills and gullies of lesser depth where erosion is excessive or where rill and gully formation is detrimental to reclamation success. Colorado Yampa Coal Company's plan to reclaim excessive rills and • gullies which are neither part of the monitoring program nor permanent drainageways will include on or a combination of several techniques. One method used consists of backfilling, seeding, and then contour furrow TR 89-04 24-4 Revised 5/10/89