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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. be applied again this year. The long term average annual precipitation in the mine area is approximately 11-12 inches. A couple of potential concerns were discussed with the operator. First, smooth brome is marginally adapted to upland sites in this precipitation zone under dryland conditions and would not be expected to persist long term as a significant stand component. It is recommended that the operator consider amending upland, dryland seedmixes to delete smooth brome. Second, it would seem that the irrigation application rates for dryland establishment may be excessive, and could possibly result in shallow root development that would negatively affect survival of desirable species after irrigation i$ terminated. It may be appropriate for dryland sites being irrigated for initial establishment to receive lower application rates than irrigated cropland or pastureland. As ` mentioned above with respect to Mine 2, the site should be closely observed in future years after irrigation is terminated to monitor how the vegetation stand adapts to dryland conditions. The operator stated that the landowner had indicated an interest in having the Rice tract designated as irrigated pastureland, rather than dryland pasture. The permit would need to be appropriately revised to reflect such land use change, but I indicated that if the change was supported by the landowner, I could see no apparent reason that would preclude Division approval of the change. , The final areas viewed were a reclaimed rangeland parcel in the vicinity of Pond 5, at Mine 2, and the upland sagebrush reference area near Pond 6. The reclaimed site was apparently seeded in the late 1980's, and the operator had applied for Phase 2 bond release a few years ago. Phase 2 bond release was denied due largely to excessive cheatgrass, and an early spring grazing program was subsequently instituted to attempt to reduce the cheatgrass. At the time of the inspection, cattle had been off the site for only a week or so, and almost all vegetation had been closely cropped, making species identification somewhat difficult. It appeared that the two week grazing period was probably somewhat too late in the spring this year. To be most effective, the grazing would need to be carefully timed to be initiated just prior to seed maturation, which would probably be early to mid-May in most years. Although it was apparent that considerable cheatgrass was present in the stand, an effective cover of perennial species including four wing saltbush, western wheatgrass, intermediate wheatgrass, crested wheatgrass, and scarlet globemallow appears to have been established. Vegetative cover on the reclaimed area appeared to be somewhat lower than on the reference area, but this may be due in