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Renner <br />June 26, 1987 <br />Page 5 <br />exception of 1981 reclamation, the average percent <br />composition of production attributed to alfalfa was <br />40 percent or lower. It also indicated that the <br />composition was also highly variable within the <br />proposed pasture. -The management outlined above <br />should reduce the opportunity for bloat in any <br />problem areas within this pasture. <br />Finally, on a mine-wide scale, the areas of high alfalfa <br />concentration constitute 100-150 acres. Reduction of <br />alfalfa seeding rates over the last three years and a <br />change from the common hayland alfalfa (Medicago sativa <br />type) to rangeland or prostrate alfalfa (Med~ falcata <br />type) as approved in the permit renewa process, will <br />adequately control alfalfa in the future. Thus, <br />mine-wide, less than 10 percent of the total reclamation <br />is included in the problematic areas. <br />In summary, the alfalfa management and control plan <br />presented to CMLRD on April 12, 1987 eliminated the <br />herbicide application option and concentrated on grazing <br />for both short-term and long-term goals for the following <br />reasons: <br />Herbicide applications cannot be selective enough to <br />prevent perturbation of desirable species (both <br />shrubs and fortis) within the areas of high alfalfa <br />concentration. Even within these areas alfalfa <br />concentrations, while high overall, are not <br />continuous. With herbicide control the chances of <br />needing, unnecessarily, to totally reseed 100-150 <br />acres is high. <br />The short-term and long-term goals of reducing <br />alfalfa concentrations and increasing shrub and forb <br />components can be achieved by heavy grazing at first <br />and then adjusting stocking rates as dictated by <br />monitoring results. <br />c. The areas of high alfalfa concentration outside of <br />the grazing unit are primarily prelaw areas and, <br />while limited in area, provide a valuable wildlife <br />resource, as well as being suitable for range grazing <br />of livestock. As stated on Page 116 of the 1985 <br />Revegetation Monitoring Report: <br />"Even though alfalfa occurs at high levels ., it <br />is important to emphasize that the existing <br />vegetation on the reclaimed areas provides good <br />quality forage for livestock and native wildlife <br />species". <br />