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As stated, the recently submitted alfalfa management plan is specific <br />to grazing only. No where does PCC address why selective herbicides <br />were dropped from consideration. In lieu of the magnitude of the <br />problem (see Table 1) and the number of acres infested at this site, I <br />do not believe the management plan should be restricted to grazing <br />only. I believe we are in the experimental stage where a variety of <br />management tools should be used to try and alleviate the problem and to <br />determine the best management tool to use in future years. Therefore, <br />fora portion of the proposed 303 acre pasture or for the small, <br />scattered parcels other than this pasture as referenced on page 13-3-5, <br />PCC should be encouraged to utilize selective herbicides. A comparison <br />can then be performed between herbicide control areas versus grazing <br />control areas to determine effectiveness. <br />TABLE 1* <br /> Total Alfalfa Alfalfa Alfalfa <br />Year Cover Cover Frequency Species Ranking <br /> <br />1977 40.9% 20.2% 50.0% 1 <br />1978 58.6% 23.1% 90.0% 1 <br />1979 52.3% 32.5% 93.3% 1 <br />1980 36.0% 16.8% 75.0% 1 <br />1981 35.8% 24.8% 90.0% 1 <br />1982 23.6% 8.1% 84.0% 1 <br />1983 18.8% 1.3% 55.0% 5 <br />*Keammerer, Warren R., Evaluation of Reclaimed Areas on the Seneca II Mine. <br />Stoecker - Keammerer and Associates, Boulder, Colorado, December 1985. <br />The proposed 303 acre pasture is portrayed on new "Map 1 to <br />Appendix 13-3." It is unclear from the material submitted and from <br />review of the Seneca II permit application what years of reclamation <br />will be included in this pasture. A review of Table 1 (above) would <br />indicate that all areas reclaimed in 1977 to 1982 should be included <br />within the alfalfa management plan. <br />3. As alluded in point 1 above, the Division views the management of <br />alfalfa as experimental at this time. As such, the Division is <br />uncertain if it is prudent to specify one stocking rate for the proposed <br />303 acre pasture. The Division believes splitting this proposed large <br />pasture into smaller units would allow for variable forage utilization <br />rates. While it is true that this may entail more work by PCC, the <br />benefits of determining proper utilization mitigate this concern. <br />