2014-10-21_REVISION - M1988044 (5)

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TR-07 RECLAMATION PLAN has a much wider habitat tolerance range than Leafy Spurge and therefore is a far greater threat in the upland areas. Fortunately, the current Knapweed population is confined and small. Current efforts are directed at complete eradication in the area where it is currently found and eradication elsewhere if it is found elsewhere. In many respects, Knapweed is potentially far more damaging than Leafy Spurge because it can grow in a wider variety of habitats. Where the spurge exists it is extremely damaging. But the spurge, along with Canada Thistle, tend to have a narrower survival habitat range than Knapweed and is therefore naturally more limited in its expansion. Knapweed can grow practically anywhere except in wetlands and can expand many times faster than Leafy Spurge or Canada Thistle. Knapweed can grow very nicely in a crack in a large rock; spurge cannot. Other weeds of some concern are the tumbleweeds,Kochia and Salsola. But these common tumbleweeds do not appear to be a major problem on this property. They can be found almost everywhere, but their population is generally small and even where they do occur in moderate abundance the individual plants tend to be small. However, in the reclamation condition, where nutrient levels are often severely distorted, these tumbleweeds can become a very severe problem. In the past, that has not been the case, even when soil and overburden stockpiles have large and robust populations. Why these two species have not been a problem in the older revegetation is not known, but rampant and robust growths of these species should always be anticipated in future reclamation areas. Such growths may never develop, but they should be watched for very closely. Much of the weed management plan for these mining areas must necessarily be a part of the larger weed management plan for the entire property. Without management elsewhere, management of weeds on the mining property does not make a great deal of sense in the larger picture. Nevertheless, whether there is a generalized management plan for the entire property or not, weed management on the lands affected by the operation is required by law and by rules. Therefore, at the minimum, weed management on the affected lands will be implemented irrespective of what is implemented elsewhere, even if nothing is done elsewhere. If there is a more widespread management plan on unaffected land that is being implemented by the State Land Board (the landowner) or by other lessees then the management of weeds on the mined lands will be coordinated with those plans. In general, native invaders that exhibit weed-like growth should not be controlled. These are called pioneer species and are an important part of the vegetation development process. They may not look good or may appear to behave badly, but they are there because that is the way the system naturally develops. The native invaders should be allowed to "do their thing." In time the system itself will control them through natural means. This particularly applies to the cactus, yucca, fringed sage, some of the other sages, and many of the native wildflowers. Many of these plants fix large amounts of nitrogen, redistribute nutrients in the system, help keep the soil mixed, and prepare the soil for domination by grass. (TR-07 Note: Over the last several years, considerable success has been achieved in reducing the degree of Leafy Spurge infestation on this property. Much of this species has all but been eliminated in Coal Creek Sand Resource Amendment 3 (2005)- M-1988-044 Exhibit E Page 22