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Tonya Hammond <br />September 4, ?0?9 <br />Page ? <br />o rec?air?e? area s?a?I have ? si?g?e species ??at represents greater than <br />70% relative cover, wi??Z ??e exception of an?ua? grasses, ?e a?r?u? <br />grass co?nponer?? saii r?o? exceed 7?% reia?ive cover u?%ss the un?u?l <br />grass copor?er?? ? tie ?orre?pod??g reference area aiso exceeds 70%, <br />,?? such casesr ?e reia?ive cover o? ??e un?uad ?ras ?or?po?er?? o,?the <br />reclai?ne? area s?a?i ao? eceea? tie reiative cover o ?e an?uai grass <br />copo?ea? % ??e reference area ?y more ??? S%. <br />The reason the diversity standard provision was revised in ???? was to address the very <br />concern raised in CFA's recommendation. Although the approach that was taken to <br />addzess the concern differs from that recommended in the ??oS report, Mere was <br />concurrence among D1VI, snowcap, and CAA in X005 that the revised provision was <br />acceptable. <br />Please let us knov? and provide explanation and justification if you believe the <br />appxoved provision is no longer appropriate, <br />??r???nr? 4.? <br />?. generalized recommendations included in this section address the heavy chetgrass <br />presence in many ofthe reclaimed locations, and lack ofadequate representation of <br />partlcular 11fe form categories ]n numerous areas. The report notes that in many cases, <br />the locations deficient in one or mare categories, such as warm or cool season grasses or <br />perennial forbsfhalf shrubs, are open characterized by high cheatgrass cover, and that in <br />order to achieve improvement in these locations, cheatgrass suppression efforts followed <br />by interseeding would be warranted. The section includes general recommendations <br />concerning cheatgrass control and interseeding strategies, and also includes a suggested <br />seedmix Ito be ordered separately by species to tailor interseeding efforts according to the <br />deficiencies presented in particular areas}. <br />In order to be implemented, the proposal would need to be formalized and submitted in <br />the form of ? technical revllon application. we do concur with the general conclusion <br />that n?anagernent measures including cheatgrass suppression and interseeding will likely <br />be necessary in numerous locations, in. order for reclaimed areas to meet life form <br />diversity standards within reasonable time frames. we offer the following comments: <br />• Any plan for further cheatgrass suppression and interseeding should include <br />assessment and evaluation of the previous effort undertaken at the North Decline <br />area, which apparently resulted in only temporary suppression of cheatgrass, with <br />no significant establlshrnent of seeded perennials. It may be ofbenefit to request <br />the assistance of area weed district supervisors ?e.g. Mesa and Barfield County <br />. weed Control}, state Agriculture Department staff, and other authorities with <br />cheatgrass control experience, in developing aiay plans for further cheatg?ass <br />suppression and interseeding for reseeding} efforts. Because BAS` product