2009-09-04_REPORT - C1981041 (2)

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Tonga Hammond sep?ember 4, ?0?9 Page 2 o reciairne? area sha?I have a since species that represents greater than 70% relative cover, with the exception of annual grasses, ?'he annaai grass component shall not exceed 7?% relative cover un%ss the annual grass copor?er?t ? the ??rrespondir?g reference area also exceeds 7?%. ,fin such casesr the relative cover o? f tie ?nnaud grass ?o??o?en? of the reclai?ne? area sha?i not exceea? the relative cover of the a?nuai grass component in the reference area ?,? rnure than ?%. The reason the diversity standard provision was revised in 2005 was to address the very concern raised in CFA's recommendation. Although the approach that was taken to address the concern differs from that recommended in the SODS report, there was concurrence among D1VI, snowcap, and CA ?n ??05 that the revised provis?an was acceptable. Please let us knov? and provide explanation and bus#i?ica#ion i? you heueve the appxoved provision is no longer appropria#e, section 4,? ?. enezalized reconendations included in this section address the heavy cheatgrass presence in many ofthe reclaimed locations, and lack of adequate representation of particulax life form categories ?n numerous areas. The zeport Hates that in many cases, the locations deficient in one or more categories, such as warm ar coal season grasses ar perennial forbs?half shrubs, are open characterized by high cheatgras cover, anal that in order to achieve improvement in these locations, cheatgrass suppression efforts followed by interseedin would be warranted The section includes general recommendations concerning cheatgrass control and interseeding strategies, and also includes a suggested seedmix eta be ordered separately by species to tailor interseeding efforts according to the deficiencies presented in particular areas}, In order to be implemented, the proposal would need to be formalized a?ad submitted iii the form of a technical revl1on application. e do concur with the general conclusion that management measures including cheatgrss suppression and interseeding will likely be necessary in numerous locations, iia order far reclaimed areas to meet life form diversity standards within reasonable time frames. we offer the following corn?nents: • Any plan for further cheatgrass suppression and interseeding should include assessment and evaluation of the previous effort undertaken at the forth Decline area, which apparently resulted in only temporary suppression of cheatgrass, with no significant establishment of seeded perennials. It may be ofbenefit to request the assistance of area weed district supervisors ?e,g. Mesa and Barfield County . weed Control}, state Agriculture Department staff, and other authorities with cheatgrass control experience, in develap?ng ar?y plans for further cheatgrass suppression and interseeding for reseeding efforts. Because BAS` product