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iii iiiiiiiiniii iii 999 Matthew S. Hayes Hayes Environmental Services 1367 S. Humboldt St. ~ ~ ~ ~a ~ Denver, CO 80210 ~ ~ s (303) 733-5368 JAN 141993 January 13, 1993 Mr. Dan Mathews Division of Minerals and Geology 1313 Sherman St., Room 215 Denver, CO 80203 RE: Various vegetation issues. Dear Dan: DIVIS;p;;; i ~._ IWINEf3,gLS ~i .V%L. ~ ~ • ~,, Sorry to send this letter so late. We discussed it's contents in late September, but I have not had free time to send it until now. I hope you are still interested. This letter is partly follow-up on our September phone conversation, though item 1 is new. 1. Status of Yellow sweetclover (Melilotus officinalis). If I remember correctly, Yellow sweetclover has long been included and approved of in mine reclamation seed mixes. My understanding is that it was mistakenly considered to be a perennial forb. I had always assumed this was the case and was surprised to learn that it is a biennial. On page 5 of Christine Johnston's September 2, 1992 letter to Jim Stover (RE: Preliminary Adequacy Review; Renewal 02; Blue Ribbon Mine; File Nc. C-81-047), it is noted that Steve Shuey recommended, "Pursuant to Rule 4.15.1(1) which states that reestablished vegetation must be permanent, Yellow sweetclover (Melilotus officinalis) cannot be included in reclamation success standards as it was in the vegetation monitoring report submitted February 18, 1992...." I would argue that "permanent" is not necessarily interchangeable with "perennial". Mr. Shuey in fact goes on to recommend that Yellow sweetclover be cut back and uprooted, implying that the species is aggressive and may dominate or increase in the locations where it is found. The implication is that unless controlled, this species will be a permanent feature of the reclaimed vegetation. Additionally, biennial forb species are on occasion encountered in natural and\or reference area communities. I