Laserfiche WebLink
Mr. Fred Banta <br />August 'L9, 1959 <br />Page 2 <br />Adding another regulatory level to the easily targeted <br />surface coal mining industry is not the solution to this <br />wide spread problem. <br />An effective state-wide weed control program which <br />requires all operators, and in particular, agriculture <br />operators, to control noxious weeds may be the only <br />workable solution. <br />Section III <br />The operators will be required to monitor annually for <br />noxious weeds (new infestations and responses to weed <br />control in older areas). Any changes to the plan or <br />locations of weed infestations will require a minor <br />revision. This could require a change in the plan and a <br />minor revision application on an annual basis which will <br />result in significant additional levels of paperwork and <br />administration. This goes bzyond any current requirement <br />for monitoring reclaimed areas for vegetation success and <br />reporting on these monitoring results. The requirement <br />for a detailed location map and accompanying narrative for <br />all areas of infestations further compounds the effort. <br />The requirement to have the minor revision in by August 1 <br />adds to administrative problems and could put the operator <br />under an unrealistic time frame. As an example, Peabody <br />completes revegetation field studies by the szcond or <br />third week in July. As part of these studies, locations <br />of potential noxious weed areas are noted. We would be <br />hard pressed to meet an August 1 deadline because of the <br />data reduction, documentation, and paperwork required. <br />Though we would rather have no set date, it appears that <br />January 1 would be a more workable alternative. Can a <br />weed control plan be prepared that will remain functional <br />for several years without having tG add to the already <br />excessive levels of paperwork and 'administration (in the <br />context of permitting and current permits)? The <br />specificity required ire the policy is too strict. Amore <br />general weed control plan would achieve the same results <br />while providing needed flexibility to the operator. <br />Additionally, reporting required for thz weed control plan <br />should be incorporated in reclamation monitoring reports. <br />How will the Division document infestations of noxious <br />weeds as specified in l.a. and l.b. of the proposed <br />policy? is the Division going to collect cover data in a <br />manner which is consistent with the present CMLRD <br />vegetation guidelines (i.e., point intercept method and <br />sampling to adequacy) or is the DivisiGn going tG rely on <br />