GENERAL36822

• Permit No: C1980005
• IBM Index Class Name: General Documents
• Doc Date: 7/2/1987
• Doc Name: ALFALFA MANAGEMENT AND CONTROL PLAN SENECA II MINE PN C-80-005
• From: PEABODY COAL CO
• To: MLRD
• Permit Index Doc Type: VEGETATION
• Media Type: D
• Archive: No

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PEABODY COAL COMPANY
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June 26, 1987
1300 South Vala
Flagstaff, Arizona 86001
(602) 7745253

Mr. Steve Renner
Colorado Mined Land Reclamation Division J UL 2 X987
423 Centennial Building MINED LANV
1313 Sherman Street RECLAMATION DIVISION
Denver, CO 80203
RE: Alfalfa Management and Control Plan, Seneca II Mine
Permit No. C-80-005
Dear Mr. Renner:
The Alfalfa (Medics o sativa) Management and Control Plan
as submitted pril 12, 1987) in response to CMLRD review
of revegetation monitoring presented during the Seneca II
Permit renewal process (and discussed conceptually with
Mr. Mike Savage of your office on April 2, 1987),
recognizes that the amount of alfalfa that is occurring in
some of the earlier reclamation (prelaw, 1979, 1980, and
1981) was having some detrimental affects on shrub
densities and overall species diversity. CMLRD's review
of this plan, as detailed in your letter of May 18, 1987,
noted a difference in approach in managing these areas
between what was discussed in the August, 1986 Preliminary
Adequacy Review and what was submitted in the finalized
plan. Following is a discussion, using the same format as
your comment letter of May 18, 1987, addressing these
questions.
Item 1.
Peabody's initial thoughts regarding reduction of alfalfa
in some of the earlier reclamation were based on two
assumptions. First, it was assumed that excessive alfalfa
was a wide spread problem in the early reclamation. This
assumption was based on the summary data presented in
Appendix 13-3 in the 1985 Reclamation Monitoring Report.
Secondly, it was assumed that severely impacting alfalfa
in all areas with high levels was a necessity for a
control program to be successful. Based on those
assumptions, use of herbicides in the heavier stands of
alfalfa was presented as the most direct means to impact
those stands. Further review of the data, discussions
with Colorado Division of Wildlife, and review of the
potential impacts of herbicide application to overall
reclamation goals have modified our view regarding use of