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Doug Smith <br />Page 2 <br />February 29, 2016 <br />required for use on BLM and USFS lands (described in Tables 4 and 5 of Exhibit 2.05- <br />E6, respectively). <br />Weeds identified as requiring control during 2015 were "thistles, hounds tongue and <br />Whitetop". Oxbow employees and contractors sprayed disturbed areas with Crossbow <br />and Curtail herbicides. These products are manufactured by Dow Chemical and are <br />approved for use in Colorado. Curtail is described as "a broad-spectrum broadleaf <br />herbicide providing outstanding control of Canada thistle and other problem weeds in <br />small grains", and is mentioned specifically in the weed control plan in Exhibit 2.05-E6. <br />Crossbow is described as "a postemergent product that targets woody plants and brush — <br />such as blackberries and poison oak — as well as annual and perennial broadleaves, while <br />leaving grasses unharmed" but appears to have been discontinued by the manufacturer. <br />Since the use of Crossbow is not specifically approved in Exhibit 2.05-E6, please explain <br />why it was chosen rather than any of the products that are mentioned by name in the <br />permit. <br />Reclaimed areas were inspected for rills and gullies deeper than nine inches, but none <br />were identified. <br />The 2015 ARR identifies 97.60 acres that have been backfilled and graded and are therefore <br />presumably eligible for Phase I bond release; and 42.85 acres that were seeded at least 10 years <br />ago, and could be eligible for Phase II/VI bond release. <br />Finally, the 2016 ARR is due by February 15, 2017. Please plan to include details of any weed or <br />erosion control, re -seeding or vegetation sampling that takes place in 2016. <br />Sincerely, <br />Leigh Simmons <br />Environmental Protection Specialist <br />