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smooth brome, with a relatively minor weedy component. This grassy patch may comprise <br />approximately 20% of the non-brushy flats west of the office. <br />"East Flats" <br />The small non-brushy area east of the office and pazking azea contains a relatively large patch of <br />a low growing, spreading Polygonum (knotweed), which has lazgely prevented the <br />establishment of desirable vegetation over a third or more of the azea. The remainder of the <br />East Flats area supports a modest stand of seeded perennial grasses and forbs, along with <br />vazious annual and perennial weeds, and some cheatgrass. <br />Considerations and Recommendation <br />The "West Flats" and "East Flats" areas described are excessively weedy and support a <br />generally poor stand of desirable vegetation. Weed control efforts and reseeding would appear <br />to be warranted. Interseeding "without restarting the clock" pursuant to 4.15.7(5)(8) would not <br />appear to fit this case, because the purpose of treatments would be to replace existing stands that <br />are dominated by species which do not support the approved post mine land use. It is not <br />entirely clear to me, but is probably doubtful that the operator would be able to make the "less <br />than five percent of the acreage reclaimed in any one yeaz" demonstration, with respect to <br />treatment and reseeding of the weedy areas [pursuant to 4.15.7(5)(b)], since the flat azeas were <br />appazently revegetated several years after the portal slopes were revegetated. The most logical <br />approach may be for the operator to coordinate treatment and reseeding of the weedy areas in <br />conjunction with grading and seeding of the adjacent office and pazking azea, with the entire <br />"flats" area to be managed as a single unit with respect to ultimate bond release. <br />I would suggest that you request the operator to provide a remedial treatment plan for the weedy <br />flats azeas, in conjunction with the grading/topsoiling/seeding plan for the office and parking <br />area. <br />