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top of page V-31 is relevant to the issues raised in Item 1 of this letter. The <br />concept described is that "as natural successional stages advance, the <br />ecosystem will mature by the continued growth of the shrub component and <br />dispersion and establishment from adjacent endemic ecotypes and species". <br />This successional sequence may be disrupted or severely delayed by use of the <br />aggressive, persistent, introduced grasses. Various other Items in the "General <br />Revegetation Practices" section related to diversity enhancement and <br />establishment of big sagebrush and other native species with very particular <br />establishment requirements are relevant if the emphasis of the revegetation plan <br />is to establish relatively diverse communities that will develop as described in <br />Item "a". However, the diversity enhancement concepts and goals described <br />may not be compatible with use of the introduced grasses. <br />If it is ultimately determined that the goal described in Item "a" is appropriate, it is <br />likely that seed mix(es) will need to be revised, and that seeding practices in <br />subsequent sections of the revegetation plan will need to be amended to <br />incorporate and further develop the various diversity and shrub enhancement <br />practices discussed in the "General Revegetation Practices" section. <br />Conversely, if it is determined that rapid establishment of a competitive, <br />persistent, perennial grass cover is the appropriate objective, then several of the <br />Items in "General Revegetation Practices" may need to be revised. <br />As with Item 7, please take these points under consideration and provide <br />an initial, conceptual response within your mid-term review response <br />submittal. <br />10. Narrative on page V-51 related to herbicidal cheatgrass control and remedial <br />seeding trials conducted on portions of Refuse Area #1 in 2000 is written <br />prospectively. Please update the narrative to describe the results achieved <br />and the current vegetative status of the remedial treatment areas. Please <br />include description of treatment, results, and current status of vegetation <br />cover on Topsoil Stockpile 213, near RP-1, which was also treated in 2000. <br />Also, please address the implications of these and other cheatgrass <br />treatment trials, and how the results have been incorporated into on-going <br />cheatgrass control efforts applied to reclaimed areas, topsoil stockpiles, <br />and other stages of disturbance and reclamation. <br />11. The introductory paragraph of permit section V.J.1, on page V-53, should include <br />reference to Rule 4.15.11, which was incorporated into the DRMS regulations in <br />2005, in addition to the other rules cited. Also, because Rule 4.15.11 addresses <br />acceptable revegetation sampling methods and statistical demonstrations for <br />revegetation success, the reference to the DMG "Guidelines Regarding Selected <br />Coal Mine Bond Release Issues", in the introductory paragraph of permit Section <br />V.J.3, page V-63, should be replaced with reference to Rule 4.15.11. Please <br />12 <br />