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<br />July 1, 1991 <br />Mr. Randall P. Price <br />Page 2 <br />The Division was also consulted with regarY3 to the timing of the 1991 spraying <br />program. The contractor xeam¢nended fall (mid-August) application as plants <br />exhibit a growth spurt to store nutrients for winter, as mav;enim vegetative area <br />is available for herbicide absorption, arri as all new sprouts for the season are <br />available for spraying. The Division wncur~-ed with this xeasortirxJ but has <br />indicated some concern over the potential for seed dispersion during the interim <br />period and has suggested some type of physical control aimed at the destruction <br />of seed heads may be appropriate. <br />After further consultation with the contractor, OOVCC concludes that the <br />additional control potentially gained frran physically removing individual seed <br />heads prior to dispersion is insignificant. The contractor notes that the <br />primary reproductive mode of the Canada Zhistle is via root extension and that <br />while innumerable seeds are produced, very few encounter the appropriate <br />combination of conditions required for establishment. In addition, the <br />contractor suggests that the majority of seeds will remain attached to the plants <br />until after the proposed spraying windaa and will thereby be controlled by the <br />spray itself. The majority of any seeds which do disperse will fall within a <br />small radius at the base of the plant and will again likely be controlled by the <br />spray. lastly, the 1991 weed control program is again urriertaken with the <br />knowledge that a continuing, annual spraying program will be rqqui_ed to achieve <br />effective long-term control. In consideration of these factors, COVCC does not <br />at this time intern] to implement a physical wntrol effort prior to the fall <br />spraying unless direc,-ted to do so via cammrnication with the Division. COVCC <br />believes this proposed plan of action adequately, responsibly, and cost <br />effectively meets its obligation to control this weed. <br />In accordance with minor revision 68, the following modified product <br />list/application rate is submitted to the Division for approval prior to <br />utilization: <br />To 98.5 gallons of water, add the following: <br />0 1 gallon of Toulon 22K -EPA No. 464-323 <br />0 2 pints LI 700 -EPA exempt <br />0 2 pints Hi-light spray indicator -EPA exeag>t <br />If you have any questions, please contact me at 303-527-4135. Thank you for your <br />cooperation in this matter. <br />CYPRUS ORQiARD VALLESC GOAL <br />Karl C. Koehler <br />Etrvirornrental Specialist <br />cc: C[~RD General Correspondence file <br />I~II290-68 file <br />