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significantly different in suspended solids to that of the <br /> undisturbed areas for most runoff events . <br /> It should also be noted that on these road fill slopes , of <br /> 1 . OH : 1 . OV grade , total equilibrium will never be reached . It is <br /> also not reached on the natural slopes of the area. <br /> 2 ) After reviewing the permitting record , it is seen that Mid- <br /> Continent has done considerable work on erosion control on the <br /> roads over the years , some of it on its own initiative and some of <br /> it at the recommendation or demand of the Division . <br /> In 1991 , Dan Mathews of the Division conducted a three week long <br /> investigation that resulted in some specific corrective actions . <br /> Ail of the corrective measures . such as rip-rap , culvert outlet <br /> troug'r;s or downspouts , water bars , regrading road ditches , etc. <br /> were completed by Mid-Continent . in fact , it is my understanding <br /> that all specific requests made of Mid-Continent by the Division <br /> throughout the time of the permit have been performed . The record <br /> also shows that Mid-Continent has planted trees in many road slope <br /> areas and has applied seed and mulch to most other areas . I have <br /> seer; some general statements in the correspondence such as "erosion <br /> must be controlled over all road areas" . I realize that the reality <br /> o' the ground makes it extremely difficult to take action based on <br /> unspecific statements such as these . From site inspections and <br /> review of the permitting record , I believe that Ni-id-Continent has <br /> made an effort to control erosion on these pre- law roads to the <br /> extent reasonable and practicI . The effort to the extent reasonable <br /> and practical must be emphasized for these pre- law roads in the <br /> type of terrain and soil conditions in which they exist . <br /> 3) In certain areas , the gullies on the fill slopes have not <br /> reached relative equilibrium. These areas are not very widespread , <br /> but they do exist . In these areas , the fill material is usually <br /> comprised of a durable type of Marcos Shale as a result of past <br /> geologic intrusives . This material generally breaks up into <br /> granular and gravelly textured material but does not form clay or <br /> loam. Therefore , it has no cohesive strength . The fill slopes were <br /> able to be placed at a steep angle simply due to the fact that the <br /> angular nature of the material gives it a high angle of friction . <br /> The gravelly nature of the material causes two problems : a) it <br /> erodes easily with any appreciable surface flow and b) it is <br /> difficult to establish vegetation in the material because roots <br /> cannot anchor themselves without appreciable fine material . The <br /> enclosed photos show an area from the Mine #3 road that represents <br /> a problem area of this type . <br />