GENERAL34011

• Permit No: C1980005
• IBM Index Class Name: General Documents
• Doc Date: 5/13/1987
• Doc Name: PEABODY COAL CO SENECA II MINE ALFALFA MANAGEMENT AND CONTROL PLAN PN C-80-005
• From: MLRD
• To: STEVE RENNER
• Permit Index Doc Type: VEGETATION
• Media Type: D
• Archive: No

III IIIIIIIIIIIII III
999
STATE OF COLORADO
Roy Romer, Governor
DEPARTMENT OF NATURAL RESOURCES
MINED LAND RECLAMATION DIVISION
DAVID C. SHELTON, Director
DATE: May 13, 1987
T0: Steve Renner (~~~
FROM: Peter O'Connor \~'
RE: PEABODY COAL COMPANY - SENECA II MINE - ALFALFA MANAGEMENT AND CONTROL
PLAN - PERMIT N0. C-80-005
As requested, I have reviewed the above referenced plan submitted by Peabody
Coal Company (PCC) on April 12, 1987. This plan was submitted to resolve a
commitment made by PCC during permit renewal as addressed on pages 24 and 25
of PCC's August 29, 1986 PAR reply letter and on page 34 of the
December 31, 1986 Findings Document (Section XII - Vegetation). Due to delays
encountered by PCC, the Division agreed to extend the submittal date from
February 1, 1987 to April 15, 1987.
The plan submitted by PCC specifically addresses attempting to control the
alfalfa infestation problem at Seneca II by grazing. PCC proposes fencing off
303 acres of reclaimed area which will be grazed by either cattle or sheep.
Initial animal stocking rate will be set so that animal utilization will be
approximatey 75%. (Typical stocking rate is around 50% forage utilization;
the higher rate is "...to insure that desired impacts to the alfalfa component
and the overall vegetation stand can begin to be realized.") Grazing will be
anywhere from mid-May through late-October. Grazing in future years will be
at approximately 50% forage utilization.
Based on mY review, I have a number of concerns as addressed below.
1. The August 1986 PAR reponse letter addressed a two-fold management
plan: short-term goals of eradication or significant reduction of the
alfalfa population; and long-term control and management of the
remaining stands. As noted on page 25, "Eradication or significant
reduction of the alfalfa stands over the short term can best be
accomplished by application of a selective broadleaf herbicide which
will allow for survival of graminoids in the stand. While some fortis
and shrubs will also be lost, it is anticipated that the extensive
alfalfa canopies will intercept much of the spray, thus shielding to
some degree more desireable broadleaf plants." The long-term control
and management would be accomplished by a grazing management plan.
The Division agreed to the concept of the two-fold management plan
because of the flexibility it provided to PCC. There are no
certainties that grazing only, herbicide only, or one management
technique only will be able to control the alfalfa problem. The
presented two-fold plan allowed for variability in attempting to
resolve the infestation problem.
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. [phone]