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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. in combination with site specific sampling data from baseline investigations and former reference areas. Regulatory issue regarding extent of OSM involvement in approval of technical standards will need to be considered. For shallow soil rangeland sites, the applicability of the original rangeland reference area may warrant consideration. For deep soil rangeland sites, is the current airport fenced rangeland site appropriate, or is it also overly dominated by forbs? For deep soil pasture sites, the former BLM reference area may be of use as a reference area or as data to be considered in development of a technical standard. Drvland Pasture Reclamation Parcel Observations As noted in the August 29, 2005 inspection report, the Rice Tract pasture is dominated by Russian wildrye, present as relatively widely spaced clumps throughout the reclaimed site. Density is lowest on the steep south facing slopes, moderate on gentle south slopes that predominate, and higher on the small areas of north facing slopes. Seeded alfalfa is present in remnant amounts, but the dominant forb is the winter annual filaree, or stork's bill (Erodrum crcutarium), which provides a high percentage of the ground cover at present. The cover provided by filaree is ephemeral, with the foliage drying up and disappearing later in the growing season, leaving the interspaces between grass clumps essentially bare over the summer, until the filaree seed germinates in the fall. As noted last year, despite the relatively low cover at the site, no rills or gullies were observed. The operator indicated that there is significant winter use of the area by elk, and that trespass use by cattle has also been a problem in the past. Active prairie dog burrows were noted in portions of the site. Reference Area Observations Current Dry Pasture Reference Area As noted last year, the dominant perennial plant in the reference area appears to be low growing scarlet globemallow, with another perennial forb (a species of Senecio) also a major component of the stand. Grass is a minor component, essentially limited to very sparse clumps of Russian wildrye. It appears that there may have been some die-off of the wildrye or other bunchgrasses in recent years (based on dead plant bases present in the area), possibly due to the series of unusually dry years from 2000 through 2004. A variety of annual forbs and annual brome were also present in the reference area, along with scattered big sagebrush and rabbitbrush shrubs, and sub-shrubs including broom snakeweed. The annual tumble mustard that was present at high densities last year is absent from the stand this year, due to dryer conditions fall through early spring this year, Due to the predominance of the perennial forbs on the reference area (particularly the globemallow with its spreading habit, which provides high ground cover), the perennial cover on the reference area is significantly higher in the reference area than the Rice Tract pasture. Future prospects for cover success demonstration appear to be poor, unless steps are taken to improve the Rice Tract stand (possibly by interseeding to enhance the forb component), or the success standard is changed, or both. The current reference area may not be appropriate as a standard of success for the Rice Tract and other dryland pasture reclamation sites, due to the predominance of forb cover/production and relative lack of grass cover and production. Cool season perennial grasses are a preferred component of dryland pasture, and are a primary component of the dryland pasture seedmix and established dryland pasture stands. It was also noted during the inspection that the reference area is apparently located on a more productive soil type than was present in the Rice Tract and certain other dryland pasture sites prior to mining. Former BLM Drytand Pasture Reference Area A site located to the west of the current dryland pasture reference area was also observed during the inspection. This site might be more comparable to the desired dryland pasture reclamation. It is located within an old BLM sagebrush treatment area, and the cover is dominated by the introduced cool season pasture grass, crested wheatgrass. The site had been closely grazed earlier this spring, which is a primary reason it was previously 4