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The identity of native plants in the previous recommendation is <br />unclear. The Division is concerned about the possibility of <br />"leaving unseeded sties between passes with the drill". While some <br />weeds such as Russian thistle are considered at worst relatively <br />harmless, others are definitely recommended against. Canada <br />thistle, it turns out, has a relative composition of 18.15 in the <br />1986 reclamation. This is the highest percent composition of any <br />species. Canada thistle is extremely hard to control. <br />Establishing healthy vegetation, thereby eliminating as much bare <br />ground as possible, is the most effective way to avoid problems. <br />Other methods suggested in the above recommendation are typically <br />considered to be acceptable reclamation practices and are <br />encouraged by the Division. <br />8. Transplant of Native Wi~dlinas. <br />Kerr Recommendation: <br />Due to the deficiency of shrubs on areas approaching bond <br />release, transplanting of native wildlinos, should be <br />considered. Transplanting should he made during the early <br />spring as soon as the around is sufficiently dry to work. <br />These wildlinos should be obtained from adjacent areas that <br />will ultimately be disturbed by future mining activities. <br />This seems acceptable, especially if wildlinos are removed from <br />areas about to be stripped to provide live handled topsoil. The <br />operator is clear in the discussion on panes 44 and 45 of Appendix <br />A that transplants made beyond the first five years after reseeding <br />will restart the 10 year liability period. <br />9. Grazing <br />Kerr Recommendation: <br />Grazing is recommended as the primary means of manipulating <br />shrub densities and species diversity on reclaimed areas at <br />the Kerr 14ine. Implementation of a spring prazinp plan as <br />outlined in the existing permit should be initiated as soon <br />as possible and a suitable grazinc management plan allowing <br />for the routine o_razina of all older reclaimed areas should <br />be prepared as a part of the revised reclamation plan now <br />being prepared. <br />Grazing is typically considered to be detrimental to young <br />vegetation. If the operator wishes to submit a plan for approval <br />we will review it. Please include references to the "extensive <br />documentation" referred to on pane 43. <br />-8- <br />