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Mr. Fred Banta <br />August 29, 1989 <br />Page 3 <br />the operator's monitoring data? In l.a., goes the word <br />"reseed" actually mean a newly seeded reclaimed area <br />versus one which has required retreatment? If it is the <br />former, the word "seeded" or "revegetated" would be more <br />appropriate. In l.b., should the word "and" follow the <br />phrase "...25 percent relative cover..."? <br />Saction IV <br />Will vegetation sampling conducted by the operator at the <br />time of bond release suffice as a demonstration that <br />infestations do not occur? Will the Division investigate <br />the bond release area for infestations in addition to the <br />operators sampling? If so, any areas suspected by the <br />Division should be properly documented by the Division <br />using proper sampling procedures as noted earlier under <br />Section III. Again, trying to achieve a high level of <br />weed control within reclaimed areas surrounded by much <br />larger unaffected areas that have noxious weed problems <br />may be somewhat idealistic. <br />Saction V <br />How was this list of noxious weeds prepared? Please <br />provide in the policy all necessary references used in the <br />preparation of the list. Is inclusion of houndstongue <br />appropriate? This weed already occurs extensively on <br />somewhat disturbed n~*_ive rangeland adjacent to the mines <br />and along numerous roads and agricultural areas outside of <br />the mine. It occurs in reclaimed areas as an early <br />successional species and appears to drop out over time. <br />Perennial vegetation in reclaimed areas appears to keep <br />this species in check. It is known that this species can <br />be obnoxious, but does this species create the severe <br />problems some of the other species on the list do? A <br />number of other weeds on the list are also <br />annual/biennials and will most likely riot be a long term <br />or significant problem if effective perennial vegetation <br />is established in reclaimed areas as required. The <br />occurrence of these annual/biennial species un reclaimed <br />lands should not be indicative of a noxious weed problem. <br />The list should probably include only those species that <br />are the perennial weeds. <br />Saction VII <br />Provide all references used to prepare the Weed Management <br />Considerations sections. These could be helpful to the <br />operators for specific additional information or to <br />identify other sources that may be consulted. Possible <br />