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2011-12-12_REVISION - M1982015
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2011-12-12_REVISION - M1982015
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Last modified
6/16/2021 6:19:03 PM
Creation date
12/13/2011 2:15:16 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1982015
IBM Index Class Name
REVISION
Doc Date
12/12/2011
Doc Name
Submittal
From
LT Environmental, Inc.
To
DRMS
Type & Sequence
TR4
Media Type
D
Archive
No
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Problem 2: Revegetation <br />CDRMS Recommended Corrective Action <br />Response <br />Cunningham, M. <br />Page 2 <br />"The Operator has failed to establish a diverse, effective, and long- lasting vegetative cover that is <br />capable of self - regeneration without continued dependence on irrigation, soil amendments or <br />fertilizer, and is at least equal in extent of cover to the natural vegetation of the surrounding area <br />as required by Rule 3.1.10 (1) (the Rule). In addition, the planted grasses are not a part of the <br />approved seed mix." <br />"The Operator shall submit a Technical Revision with the appropriate Technical Revision fee of <br />$216.00 to the Division by the corrective action date. The Technical Revision shall outline <br />efforts to revegetate the portions of the site where vegetation has not been established. The <br />Technical Revision shall state when the site will be reseeded, the type of seed mix to be used, the <br />seed application method, the quantity of each grass species as pounds of pure live seed per acre, <br />any soil amendments to be used and methods of weed control. In addition, the Technical <br />Revision shall specify the seed mix which was used to revegetate the site." <br />During a site visit on September 27, 2011, LTE observed a variety of non -weed plant species on <br />site including but not limited to: yellow sweet clover (Melilotus officinalis), saltgrass (Distichlis <br />spicata), witchgrass (Panicum capillare), yellow rabbitbrush (Chrysothamnus viscidiforus), and <br />mountain muhly (Muhlebergia Montana). <br />However, because Carma Bayshore has several concerns regarding the approved Reclamation <br />Plan, Carma Bayshore agrees to submit a Technical Revision as proposed below with the <br />appropriate Technical Revision fee of $216.00 to the CDRMS. The approved Reclamation Plan <br />was prepared by the United States Department of Agriculture (USDA) Soil Conservation Service <br />(SCS) in 1981. The USDA SCS has subsequently been renamed the USDA Natural Resource <br />Conservation Service (NRCS). The approved Reclamation Plan called for application of top soil <br />to slopes and berms after pits are filled with water then stockpiled soil to be reseeded with <br />Russian wild rye (5 # PLS /Ac) and sweet clover (3.5 # PLS /Ac). <br />There are three primary reasons for amending the approved Reclamation Plan. First, according <br />to the USDA NRCS, Russian wild rye is not considered a good choice for erosion control <br />because it develops into stands with fairly wide - spaced plants. Second, the approved <br />reclamation plan specifies only two species of plants in the seed mix (one grass and one legume), <br />which will not provide much, if any, diversity. Lastly, Carma Bayshore has the end goal of <br />providing an aesthetically - pleasing and family - friendly vegetative ground cover for this open <br />space, and the Russian wild rye and sweet clover mix will not meet that goal due to the bristly <br />texture and frequently brown color. Therefore, it can be reasonably concluded that the approved <br />Reclamation Plan seed mix will not satisfy the requirements of Rule 3.1.10 (1) (the Rule) and is <br />not desirable aesthetically or practical for the Site's intended use as a recreational amenity as part <br />
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