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supports a modest stand of seeded perennial grasses and fortis, along with various annual and <br />perennial weeds, and some cheatgrass. <br />Considerations and Recommendation <br />The "West Flats" and "East Flats" areas described are excessively weedy and support a generally <br />poor stand of desirable vegetation. Weed control efforts and reseeding are warranted. <br />Interseeding "without restarting the clock" pursuant to 4.15.7(5)(g) would not appear to fit this <br />case, because the purpose of treatments would be to replace existing stands that am dominated by <br />species which do not support the approved post mine land use. It is doubtful that the Bear Coal <br />Company would be able to make the "less than five percent of the acreage reclaimed in any one <br />year" demonstration, with respect to treatment and reseeding of the weedy areas [pursuant to <br />4.15.7(5)(6)], since the flat areas were apparently revegetated several years after the portal slopes <br />were revegetated. The most logical approach may be for the Bear Coal Company to coordinate <br />treatment and reseeding of the weedy areas in conjunction with grading and seeding of the <br />adjacent office and parking area, with the entire "flats" area to be managed as a single unit with <br />respect to ultimate bond release. <br />The Division has two requests based on the abundance of noxious weeds and other undesirable <br />plants at the Bear No. 3 Mine site. First, the Division requests that the Bear Coal Company <br />implement an aggressive weed control plan, as detailed on pages 2.05-42 and 42a of the permit <br />application. The weed control plan includes eradicating tamarisk, which is also on the mine site <br />but was not mentioned in the site report. As a reminder, the approved weed control plan contains <br />a commitment to keep appropriate records of weed control activities and to summarize such <br />activities in the annual reclamation report. <br />Second, the Division also requests that the Bear Coa! Company submit a minor revision that <br />includes a remedial treatment plan for the weedy flats areas, in conjunction with the <br />grading/topsoiling/seeding plan for the office and parking area. <br />If you have any questions, please let me know <br />Sincerely, <br />J seph J. C~i ash <br />nvironmental Protection Specialist <br />cc: Jim Stover (J.E. Stover & Associates) <br />William Bear (Bowie Resources LLC) <br />Dan Mathews (DBMS, Grand Junction) <br />c:\word\bear3\reveglet l <br />2 <br />