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Please note: The mine names and permit numbers above are correct and accurate. To avoid <br />confusion, please ensure all future correspondence for these files are referred to by these names and <br />permit numbers. <br />ADEQUACY ISSUES <br />1. Please specify timing for spring and fall management applications, in terms of the growth phase <br />of the target weeds (ie: Bud to bloom, rosette, bolting, pre-dormant or prior to first frost). <br />2. Please revise the first paragraph of the tamarisk/Russian olive section to indicate that the Board <br />adopted amendment to the weed policy applies to all affected areas of a mine site that were not <br />reclaimed prior to January 19, 2005, not just the areas that are reclaimed. This -means that <br />tamarisk and Russian olive management must also be implemented on areas that have been <br />affected any time during the life of the mine and have not yet been reclaimed. <br />3. The tamarisk and Russian olive portion of the plan states several of the methods available to <br />control these species, but does not commit Oldcastle to implementing any or all of these <br />management techniques. Please specify which will be implemented and include specific timing <br />for each type of management technique. <br />4. Please revise the plan to state: the goal is to meet both stated criteria and the approved post <br />mining land use. <br />5. Please revise the Russian olive section to indicate that control will be implemented in the <br />summer or preferably in the fall. Some results have indicated that winter management is not <br />effective for this species and results in resprouting in the following spring. <br />6. DMG strongly recommends that all weed management events be thoroughly documented and <br />included in the annual report. Documentation should include mapping of grandfathered <br />reclamation, location and extent of weed patches, identification of species, specification of <br />management method used, timing of the treatment, and any specifics such as herbicide type, <br />mixture strength, application equipment, temperature, weather, etc. The report should also <br />include observed results of the effectiveness of the treatment and propose changes when <br />treatments are proven ineffective. <br />7. Please remember that the Golden Pit has a landowner that does not want pesticides used at <br />that location. Oldcastle may wish to address this site weed management plan separate from the <br />other mine permits due to this situation. <br />If you need additional information, please contact either of us at the Division of Minerals and Geology, <br />Grand Junction Field Office, 101 South Third Street, Room 301, Grand Junction, Colorado 81501, <br />telephone no. 970-243-6368 (Shuey) or 970-241-1117 (Means). <br />Sinc ly, <br />Russ Mea ~u~~~ <br />Environmental Protection Specialist <br />Steve S. Shuey <br />Environmental Protection Specialist <br />