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III. COMMENTS - COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made <br /> during the inspection. Comments also describe any enforcement actions taken during the inspection <br /> and the facts or evidence supporting the enforcement action. <br /> followed by the wood fiber hydro-mulch. Other backfilled and roughened slope areas associated with the <br /> South Portals reclamation project (e.g. the highwall backfill and reclaimed Access Road 1) were seeded <br /> and mulched in February (by the same method and contractor). <br /> Some recently emerged whitetop weeds (a noxious perennial species) were noted in certain locations, <br /> including the old reclaimed North Diversion ditch along the stone fence (mostly near the south end), berm <br /> behind the truck scales, and north end of the tamarisk control site along the conveyor corridor. The <br /> whitetop will need to be sprayed during April, as specified in the approved plan. <br /> A number of Scotch thistle rosettes were observed at the south end of the tamarisk control area, along the <br /> margin of the permanent reseeded conveyor corridor. Scotch thistle is a noxious biennial species, and will <br /> need to be mechanically or chemically treated to prevent seed formation. <br /> Subsequent to tamarisk control efforts a couple years ago along a portion of the conveyor corridor, there <br /> was a flush of annual weeds as well as noxious perennials (whitetop and Russian knapweed). By last <br /> summer, the dominant cover was a heavy growth of tall annual kochia, which is a summer annual. The <br /> dead brown growth of last year's kochia crop is visually dominant in the treatment area at present, but it <br /> appears that a vigorous growth of cheatgrass and associated winter annuals has taken hold in the <br /> understory. The treatment area was seeded with the approved stabilization seedmix after herbicide <br /> application, but seeded species are a relatively minor component of the cover to date. Numerous sprouts <br /> of tamarisk have also appeared since the initial treatment. Given the observation that tamarisk control <br /> efforts along the conveyor corridor and adjacent riparian habitat results in heavy growth of a suite of <br /> additional noxious and undesirable species, and given the further observation that tamarisk control along <br /> the river may not be successful unless undertaken in the context of a coordinated regional effort, it may be <br /> prudent for the operator to suspend further tamarisk control efforts within and adjacent to the riparian <br /> zone along the river, with the exception of those locations where tamarisk encroaches onto areas that <br /> have been seeded with the permanent seedmix. Tamarisk control should continue to be pursued in <br /> isolated locations away from the river corridor, such as sediment pond locations and along reclaimed <br /> ephemeral channels, as specified in the approved plan. <br /> 7 <br />