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JUL-27-1995 13:21 ROBERT DELANEY 970 945 2303 P.03 <br /> shorter growing season. Third, the slopes at Coal Basin are considerably steeper than those at <br /> Storm King. Fourth, a main concern for this work was protecting I-70 and homes from <br /> landslides. No such urgent concern exists at Coal Basin. Overall, the Storm King work cannot be <br /> compared with Coal Basin_ <br /> 3) On page 6 of the DMG request for proposal, it is stated that the road cut slopes are composed <br /> of decomposing shales and sandstones which form a talus-like slope_ Exposures of <br /> metamorphosed shale and sandstone exist in some locations. These slopes are even more <br /> unlikely to revegetate since many areas do not contain the fine-grained material for mo <br /> retention and root development. isture <br /> 4) The RFP does not specifically state how the mulch shall be applied although broadcast <br /> methods or aerial application may be used. In any case, page 20 states that crimping of the <br /> mulch is not required. It will be almost impossible for the mulch to remain on such steep slopes <br /> without any mechanism for adherance. <br /> 5)Although obvious, it is vexing to know that the majority of roads and portal benches have <br /> been reclaimed before the steep slope work is being considered, so that the new contract requires <br /> ripping and re-revegetation of miles of roads. Access crossings for perennial streams must also <br /> be reconstructed then later removed and the area revegetated. <br /> 6) The RFP discusses the fact that most of the slopes contain a crust which must be broken up <br /> prior to revegetation. This crust formed over decades after initial downslope creation and is a <br /> sign that the slopes were never disturbed by MCR after the law initiation in 1977. The DMG has <br /> argued that snow plowing has disturbed the slopes post-law. If this were true, there would be no <br /> crust on the slopes. This question gets to the root of MCR's responsibility for these slopes. <br /> 7) I feel that since the DMG is deviating from the reclamation plan in attempting to revegetate <br /> these steep slopes,the DMG should be required to explain scientifically how it expects a <br /> reasonable chance for success for this untested work in these conditions. If this cannot be done, <br /> the work should not be undertaken. Since the main objective is erosion control and since the <br /> majority of the slopes are thin sliver fills, erosion can be controlled at the bottom of the slopes <br /> utilizing catch basins or other similar structure to trap sediment. This is much more reasonable <br /> and practical. <br /> .s <br /> Sincerely, <br /> Greg Lewicki, RE_ <br /> Greg Lewicki and Associates <br />