2007-08-14_REVISION - C1981018 - Laserfiche WebLink

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8. DRMS had requested that narrative on page V-29 be updated to describe results of initial phase cheatgrass/soil factor studies, or to provide a schedule for completion and reporting of initial phase results prior to the next cycle of refuse pit reclamation. The current reclamation plan for the refuse areas approves "reverse sequence soil handling", based on observed lower density of cheatgrass and better perennial establishment on refuse area subsoil stockpiles compared to topsoil stockpiles. However, the plan also addresses field trial studies to be conducted to evaluate soil factors related to cheatgrass establishment, as well as various alternative topsoil/subsoil replacement treatments. BME responded that no analytical data has been collected to date, and that the next cycle of refuse pit reclamation is now scheduled for 2012. The BME response also indicated that "Section V.H. was modified at the top of page V-29 as requested to provide a timeline for the first phase of sampling". It appears that the referenced amended page V-29 with the requested schedule was erroneously not included in the submittal. The field trial phased study plan and schedule would be an appropriate topic of discussion at the upcoming meeting discussed under Item 7, above. If refuse area reclamation will not be initiated until 2012, it may be desirable to initiate field trial test plots within the next couple of years on suitable adjacent site locations (perhaps subsoil stockpile or reclaimed lay-down area locations). We note that Table V-7, "Revegetation Schedule..." will need to be updated to reflect the current plan, with the next cycle of refuse pit reclamation scheduled for 2012. Please give consideration to initiation of the field trial test plots prior to the next cycle of refuse pit reclamation, and provide an amended study plan and schedule for the phased field trial implementation and reporting. In addition, please submit a properly updated Table V-7. We suggest that amendments to the field trial plan be submitted after the on-site agency meeting has been held, to allow for consideration and discussion of the field trials at that meeting. 9. DRMS had noted certain apparent contradictions between conceptual goals described in the General Revegetation Practices section of the application, and elements of the approved revegetation plan, including use of aggressive introduced grasses in the seedmixes. BME responded that the conceptual goals are not necessarily at odds with use of the introduced grasses, given the very long time periods that comprise the frame of reference for the discussion of successional processes under Item "a" of the General Revegetation Practices. BME amended the subject permit section to include reference to potential benefits of using Plateau or similar herbicides for cheatgrass suppression and control of cheatgrass seedbank in topsoil stockpiles, and also included amended narrative regarding the possible need for use of monocultures of highly competitive wheatgrasses in certain situations. These issues tie in very closely to the concerns addressed under Item 7. DRMS will defer comment regarding acceptance or modification of the amended General Revegetation Practices narrative and related elements of the revegetation plan, pending the anticipated on-site meeting with BME, BLM, and CDOW.