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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The cottunents include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />This was a partial inspection conducted by Dan Mathews of the DMG Grand Junction Field <br />Office. Henry Barbe of Mountain Coal Company and Ryan Taylor of the USFS Paonia <br />District Office participated in the inspection, <br />The focus of the inspection was reclamation/revegetation of the Lone Pine Gulch Fan site <br />and associated facilities, and drill site reclamation in the Thermal Event Area and West Flat <br />Iron vicinity. Most areas observed had been reclaimed between 2000 and 2004. A number <br />of the areas had been subject to cattle grazing of varying intensity in the 2004 growing <br />season. The reclaimed areas observed appeared to be erosionally stable, with no areas of <br />excessive erosion observed. A couple locations had been closely grazed in 2004. These <br />sites appeared to exhibit lower cover and production, and in some cases a higher <br />component of annual (orbs than nearby areas that were not grazed Idue to fencing) or that <br />had been subject to lower intensity grazing (due to steep stopesl• Ryan Taylor indicated <br />that the pastures in which the recently reclaimed drill sites are located would be "rested" <br />(not subject to planned grazing) during the 2005 growing season. This should be of <br />considerable benefit. Even the apparently more heavily grazed locations have maintained a <br />relatively high composition of desirable perennial species, and these species would be <br />expected to make good growth and likely produce seed this year, given the good <br />winterlspring moisture. The operator has employed a range rider to ensure that cattle do <br />not concentrate or remain for long periods on recently seeded drill sites, and this should <br />help to ensure the successful establishment of desirable vegetation cover on the reclaimed <br />drill sites. <br />Small patches of noxious weeds, primarily Canada thistle, bull thistle, and other biennial <br />thistle species occur on some of the sites, and most weed patches had recently been <br />sprayed. In a few locations, small patches of these species had been missed, and will still <br />need to be sprayed this spring. Cheatgrass has become established in a few locations, but <br />so far the sites with cheatgrass still maintain a significant component of perennial species. <br />Yellow toadflax, a noxious species that apparently had not previously been documented on <br />the permit area, was noted in two small patches on the reclaimed waste disposal site and <br />topsoil stockpile site in lone Pine Gulch. These patches will need to be treated, and the <br />species will need to be included in future weed control efforts. <br />A reclamation practice that has been implemented on a limited basis to date for road <br />reclamation and steep slope drill site reclamation involves extensive surface roughening and <br />scattering of woody debris (slash) over the roughened surface, combined with broadcast <br />seeding. This appears to be a very effective practice, providing erosion control from the <br />combination of water retention in the gouges and raindrop interception by woody surface <br />debris, as well as providing site conditions conducive to vegetation establishment. Slash <br />may also provide seedlings some physical protection from grazing animals, and may limit <br />access by cattle to some extent during the early years of establishment. <br />For reclamation of relatively level areas, a technique that would involve "brush crushing", <br />with minimal disturbance to topsoil has been attempted on a limited scale by the operator, <br />with very encouraging results. The shrubs characteristic of the mountain shrub habitats <br />typically respond with vigorous re-sprouting following top removal, and the technique might <br />