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-~ III IIIIIIIIIIIIIIII 999 STATE OF COLORADO Roy Romer, Gove DEPARTMENT OF NATURAL RESOURCES MINED LAND RECLAMATION DIVISION DAVID C. SHELTON, Dlreetor May 18, 1987 Mr. Jim Lunan Peabody Coal Company 1300 S. Yale Avenue Flagstaff, Arizona 86001 Re: Proposed Alfalfa Management and Control Plan, Seneca II, File No. C-80-005 Dear Mr. Lunan: The Division has reviewed the Peabody Coal Company Proposed Alfalfa Management Control Plan submitted on April 12, 1987, for the Seneca II Mine. This plan, which proposes to control the alfalfa infestation at the Seneca II site by utilizing grazing techniques within a fenced area, was submitted to satisfy a commitment made by Peabody Coal Company during the permit renewal process (August 29, 1986). Based upon a review of the proposed management plan, and the permit renewal adequacy commitments, the Division has the following comments and concerns. The August 1986 PAR response 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. The short-term eradication or reduction goals would be accomplished using a selective broad leaf herbicide, while long-term control and management would be accomplished by implementing a grazing management plan. Due to the magnitude of the alfalfa infestation problem, the Division believes that the originally proposed two-fold management plan would provide the best solution to the problem. The Division suggests that Peabody Coal Company utilize selective herbicides on a portion of the 303 acre pasture area, or in the other small, scattered parcels of pasture land. By implementing this two-fold plan, comparisons between the herbicide control and grazing to determine relative effectiveness. If Peabody Coal Company elects to not pursue the herbicide application proposal, a thorough discussion justifying this decision should be submitted to the Division. This discussion should address how the short-term goals will be achieved, why the herbicide treatment as discussed in the August 29, 1986 correspondence is no longer a valid treatment, and how the smaller alfalfa infestation areas will be treated. 2. It is unclear from the material submitted ("Map 1 to Appendix 13-3") which years of reclamation will be included within the proposed 303 acre pasture area. Text or a revised map indicating which years of reclamation will be affected by the pasture area, should be submitted. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567