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Pe_y PEABODY COALCOMPANY W extern Dlvlelon iii iiiiiiiiiiiii iii 999 1300 Sown vale Plagsi all An:ona B600i (602) 7'!a 5253 August 29, 1989 ~ ~ ~: bd.>~h ~ ~' Mr. Fred Banta ~~~ k.,,;, .. Director Colorado Mined Land Reclamation Division AU G ~ 1 1969 215 Centennial Building 1313 Sherman Street 6hINE•~ LKfeL) Genver, CD 80203 ~ECLA'~FH ~ Iphl ~7P~tSic:~,a Dear Mr. Banta: The following represents Peabody's comments on the Division's proposed policy for management of noxious weeds. The comments are organized by section as presented in the draft policy memorandum. There were no comments to Sections I and VI. Section II Peabody agrees that the nature of land disturbances associated with surface mining can provide opportunities for the establishment of noxious weeds along with the more desirable seeded species. Peabody has put into effect a Division approved weed control plan to combat this potential problem. However, the occurrence of noxious weeds on reclaimed lands may represent an inevitable spread of these weeds from outside sources that are beyond the control of the surface mine operators. It is quite obvious that noxious weed problems in the immediate region of the Seneca Mine have been a problem for a number of years. Gne only need drive through the dryland agricultural.areas cf western Routt County to see that the primary cause of this is agricultural activities related to small grain farming. Canada thistle can be found on nearly all acres in these active farming areas, with many areas already at or above the infestation levels defined in the policy memorandum. Livestock grazing, particularly sheep, also has contributed to the significant spread of noxious weeds in native vegetation areas. Little or nothing is none to control noxious weeds in these areas. This results in the primary problem that combats an effective weed control program: if your neighbors ail around you do nothing, you have already lost the battle. Reclaimed areas are very small compared to total land area in the region, so the situation is further compounded.