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Permit Revision 2 <br /> Snow removal has been cited as a past problem for berm maintenance. The <br /> concern is that the snowplow has pushed the berms over the edge of the <br /> outsiope. This, in turn, inhibits vegetative growth. Berms are therefore <br /> generally not proposed for those roads which are currently kept open during <br /> winter months. Thus, for Road D, leading to Mines #1 and #2, only one bermed <br /> area is proposed. This is the site of an existing berm at an out-turn which has <br /> not been affected by past snowplowing. <br /> A berm has been constructed to prevent drainage from Road C going down the <br /> pilot road. This pilot road is a pre-law disturbance which has been vegetated, <br /> and has trees growing along the roadbed. Installation of water bars would <br /> destroy the vegetation and trees. This seems counter-productive. <br /> Further, there is no permit commitment, nor is there a design standard which <br /> requires water bars to the outside, and as this is a pre-law disturbance, <br /> reclaimed to the standards of the time, this seems inappropriate as an <br /> abatement step. The NoV essentially cites failure to follow the approved design, <br /> which does not apply. <br /> For these reasons, PR-2 does not commit to this work. <br /> We have made a careful review of each road segment, and submit, in PR-2, a <br /> plan for installation of water bars as dictated by site specific need. The water <br /> bars are proposed at 6 to 12" height, depending upon need. <br /> The 100' spacing requirement is arbitrary, and has no reference to site <br /> conditions, nor design or regulations. The 1' height essentially renders the <br /> roads un-usable to truck traffic, and is un-necessary to achieve the purpose. <br /> The Mine 2 bench has been re-graded and the berm has been enlarged as well. <br /> Straw bale check dams have been staked in place in the flow channel below the <br /> B-3 culvert outlet. PR-2 proposes installation of a berm and water bar to direct <br /> flows to the inside ditch, from 20+00 to 28+00. <br /> Concerning the road above Mine #5 to the fan installation, the installation of <br /> water bars to the outside is not feasible. The road is very narrow and does <br /> not allow equipment to do the work necessary to install water bars. In addition, <br /> the safety of the equipment operator is of great concern, given the sheer drop off <br /> the side of the road. Further, installation of water bars along this road would <br /> create serious erosion problems on the steep, erosive downslopes below. <br /> The revision proposes installation of check dams and re-directing flows from the <br /> road to improve drainage and sediment control. <br /> 4 <br />