GENERAL45853

• Permit No: C1980005
• IBM Index Class Name: General Documents
• Doc Date: 7/7/1987
• Doc Name: MEMO ALFALFA MANAGEMENT AND CONTROL PLAN
• From: MLRD
• To: STEVE RENNER
• Permit Index Doc Type: VEGETATION
• Media Type: D
• Archive: No

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999
STATE OF COLORADO
Roy Romer, Governor
DEPARTMENT OF NATURAL RESOURCES
MINED LAND RECLAMATION DIVISION
DAVID C. SHELTON, Director
DATE: July 7, 1987
T0: Steve Renner ``~/
FROM: Peter O'Connor P U
RE: PEABODY COAL COMPANY SENECA II MINE - ALFALFA MANAGEMENT AND CONTROL
PLAN - PERMIT N0. C-80-005
I have reviewed the June 26, 1987 letter from Peabody in response to your
correspondence of May 18, 1987. Your May 18th correspondence is a synopsis of
my May 13, 1987 memorandum.
The original Peabody alfalfa management control plan of April 10, 1987 only
discussed control by animal grazing. This is an adequate management tool;
however, the plan envisioned in Peabody's August 29, 1986 PAR letter addressed
a two-prong approach: herbicide control followed by animal grazing. The
April 10th submittal did not address why herbicide control had been dropped
from consideration.
Peabody's June 26, 1987 letter presents persuasive arguments for why herbicide
control should not and animal grazing only should be considered. While I
generally concur with the latest submittal, I still have reservations about
the effectiveness of only using one management technique to try and control
the alfalfa problem. This reservation is more scientifically based than
regulatory based (i.e., scientifically using a number of different techniques
would provide demonstration of which techniques are the best but also allows
for potential disaster which can not be regulatorily allowed). The safer,
regulatory approach would be to go along with the latest submitted plan. If
monitoring data reveals that grazing alone is not adequately controlling the
alfalfa, other techniques can then be implemented.
Please note that Peabody has committed to annual monitoring with the first
report and supportive data to be submitted by February 1, 1989.
cc: Mike Savage
lal
0907E
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. [phone]