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RECEIVED <br />BSEP 0 4 2015 <br />September 3, 2015 DIVISION OF RECLAMATION <br />MINING AND SAFETY <br />Mr. Tyler O'Donnell <br />Ft2... <br />Division of Reclamation Mining and Safety AGGREGATE <br />1313 Sherman Street, Room 215 <br />INDUSTRIES <br />Denver, CO 80203 <br />Re: Permit No. M-1999-034 —Cooley Reservoir and Fulton Wildlife Area <br />" TR -054 Adequacy Review Response " <br />Dear Tyler: <br />Aggregate Industries (AI) submits this letter in response to the Division's adequacy <br />review of TR -054 regarding weed control at the above -referenced operation. With regard <br />to frequency of mowing set forth in adequacy Item 1, it has been our experience that <br />frequency of mowing can vary considerably from year-to-year depending on weather <br />conditions. Additionally, as re -vegetated areas establish, the frequency of mowing <br />needed for weed control declines. Al therefore requests that the guideline for frequency <br />be based upon City of Thornton's weed control code, as submitted with AI's TR -054 <br />request; i.e., "Noxious weeds shall be kept below eight inches in height ..." [Sec. 38- <br />444. (a)(4)]. <br />With regard to weed control methods for portions of the Cooley site located east of the <br />South Platte River as set forth in adequacy Item 2, the focus of weed control in the TR - <br />054 request addressed the reservoir area owned by City of Thornton west of the river and <br />failed to provide information regarding weed control methods that have already been <br />implemented east of the river. <br />The property within the permit boundary east of the river is in unincorporated Adams <br />County. Those areas are owned or leased by Al and Al maintains a higher level of <br />control of management. These areas have been actively managed for weeds, both <br />noxious and annuals, in consultation with a qualified weed management contractor since <br />at least the early 2000's. Some mowing is done, however chemical control is the main <br />method of control as re -vegetated areas have well established grasses or are wetland areas <br />that are not conducive to mowing. <br />Weed control plans for areas east of the river are provided by AI's weed contractor <br />annually and are implemented and progressed with adjustments made as necessary to <br />Aggregate Industries <br />West Central Region, Inc. <br />1687 Cole Boulevard, Suite 300 <br />Golden, CO 80401 <br />Telephone: 303-985-1070 <br />An Equal Opportunity Employer <br />