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shorter growing season. Third, the slopes at Coal Basin al 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 moisture <br />retention and root development. <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 />beer, 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 />Sincerely, <br />614 e vieg <br />1 <br />Greg Lewicki, P.E. <br />Greg Lewicki and Associates <br />