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Jerry M. Nettleton <br />Page 12 <br />June 11, 2014 <br />a. MCM Response: The specific Permit text discussion for the Noxious Weed <br />Management Plan has been reviewed and revised, as appropriate to address the <br />CDRMS's expressed concerns. MCM completes an annual noxious weed assessment, <br />and then ties weed control activities during the year to the results of that assessment. <br />Spraying typically takes place during spring and fall, targeting different weed species. <br />Weed mapping has been included on the Reclamation and Building Demolition Map for <br />convenience, and so that all relevant maintenance and reclamation information is <br />provided in a consistent, concise format. MCM will work with the CDRMS to either <br />modify this map to address the CDRMS's concerns or will create a separate map. Copies <br />of the revised Permit discussion accompany these responses for replacement in the PAP. <br />b. DRMS Response: MCM added Hounds Tongue to the list of species to be treated in the <br />permit. The Division reviewed the 2013 Annual Reclamation Report submitted by MCM <br />and it appears weed species and control methods are discussed in the narrative of the <br />report. The Reclamation and Building Demolition Map submitted with the report <br />delineates areas where specific herbicides were used but does not indicate where specific <br />species are encountered. Revised page 5.05 -32.1 indicates the MCM maintains a <br />working weed program map and records both observed weed occurrences by weed <br />species, location, and extent of infestations; and treatment activities. Since this <br />information exists, it should be added to the Reclamation and Building Demolition Map <br />submitted in the annual reclamation report. <br />22. Permit page 2.05 -32c states that MCM will perform revegetation monitoring in the third year <br />following seeding. Several areas were reclaimed during the 2008 field season, making 2011 the third <br />growing season. MCM is reminded that revegetation monitoring is required for these reclaimed <br />areas this year. Please include the vegetation monitoring report with the 2011 Annual Reclamation <br />Report. <br />a. MCM Response: MCM is completing the required revegetation success monitoring in <br />conjunction with similar work for the nearby Seneca II and Yeast Mines. The resulting <br />monitoring information will be included with the 2011 Annual Reclamation Report. <br />b. DRMS Response: It does not appear MCM submitted the vegetation monitoring data <br />with the 2011 Annual Reclamation Report. However monitoring was conducted in 2011 <br />on 11.5 acres reclaimed in 2008 and submitted with the SL -3 bond release application. <br />According to the 2013 Annual Reclamation Report, final reclamation was completed on <br />17.1 acres encompassing the No. 9 Portal Area and adjacent Refuse Disposal Area in <br />May of 2009. Given the commitment discussed above, revegetation monitoring should <br />have been conducted on these areas in 2012. Please indicate if the 2012 monitoring was <br />conducted? <br />23. Permit page 2.05 -33 discusses the reclamation and revegetation plan that will be used on the `No. 9 <br />Portal Area/Refuse Pile ". The No. 9 Mine refuse pile was reclaimed in 2009. Please update the text <br />on permit page 2.05 -33 to include a discussion of how the No. 9 Mine refuse pile was reclaimed. <br />