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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. remainder of the regraded road shortly, along with most of the regraded water tank bench (a portion at the extreme north end was seeded and mulched in August). Minor rilling was noted along the upper segment of the regraded road (below the borrow area). The rills should be raked out in conjunction with seeding. North Decline Area The North Decline reclaimed area was sprayed in November 2005 with "Plateau" and "Roundup" herbicides to control cheatgrass, which dominated the vegetative understory to the exclusion of perennial herbaceous species. A follow-up "Plateau" herbicide treatment was applied in September 2006, and interseeding was conducted in February 2007. Soil scarification by was accomplished by ATV mounted spike tooth harrow, with minimal damage to the mature shrub overstory. Herbicide treatments over the last two years have very appreciably suppressed cheatgrass and other winter annuals, although growth of the target species was not entirely eliminated, Residual density of winter annuals varies across the site, generally higher density to the north of the permanent channel. Operator applied one additional Round-up herbicide treatment in late March in one location, where density of annuals was relatively high, and density of desirable shrubs was low. To date, there is minimal presence of seedlings from the February 2007 interseeding. There has been some emergence of cheatgrass and other winter annuals within the last week, at the site. North Portal Area Vegetative conditions have not changed appreciably. However, it was noted that the "bare area" now supports a growth of annual (orbs, though they appear to be somewhat stunted in central portions of the area. There are also a few widely scattered saltbush seedlings. General A significant acreage was reclaimed and permanently seeded within various locations in 2002. Cover and species composition of these sites were quantitatively monitored and compared to pertinent success criteria during the 2006 growing season by Cedar Creek Associates, Inc. The associated vegetation report was included in the 2006 Annual Reclamation Report. The report generally confirms qualitative observations, indicating that, in many of the individual site locations, revegetated stands are lacking in one or more components required for conformance with the diversity standard (cool season grass, warm season grass, or perennial forb/half-shrub, depending on area). Heavy growth of winter annuals, primarily cheatgrass, along with annual wheatgrass, annual barley, and stork's bill was documented in a number of locations. As noted in the report, herbicide application to control annuals, combined with interseeding of select species depending on deficient components in various locations, may be warranted. Operator may wish to delay development of re-treatment plans for these areas, pending initial assessment of North Decline cheatgrass treatment/interseeding results following the 2007 growing season. Over-all success varies considerably across the various seeded areas. Some of the apparently more successful areas, based on cover and diversity of seeded species, includes CRDA-1, B Substation, 2-West Portal substation and stockpile sites, and South Fan borrow area. The 2-West Portal, portal backfill locations are among the least successful sites. Appreciable improvement in cover and diversity of desirable species has been noted in the last couple years within the RSRDA Borrow Area and the South Fan reclaimed area. Improvement here may be due in large part to the removal of concentrated cattle grazing. Cheatgrass and other competitive winter annuals are a problem in many areas, including, to a greater or lesser extent, the North Decline, CRDA-2, areas along Coal Creek, the North Portal Area, and the RSRDA. 6