2010-07-09_REVISION - C1981019 (4)

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information to document that the entire reclaimed area was surveyed and sprayed as necessary. Third, Colowyo will need to include a plan for spraying or respraying weeds that are either missed by the contractor, do not die on the initial spraying or are late emerging, as they are found during field inspections. Fourth, Colowyo will need to include a plan for verification of the weed spraying on the ground, during or after the contractor has been on site. This will ensure that the weeds were, in fact, sprayed and that the spraying was successful in killing the weeds. This verification will also need to be documented in the Annual Reclamation Report each year. Colowyo's Response: TR-82 includes a weed management plan. Colowyo does not feel it is necessary to incorporate additional information with respect to weed control in the permit. Colowyo contracts out all weed control activities to a Certified Professional Applicator, licensed through the State of Colorado. He conducts actual on the ground surveillance of all areas within the current permit boundary including reclamation areas, and applies herbicide treatments as needed. Colowyo is provided with daily reports detailing treatment locations, weeds encountered and sprayed, volume of herbicide applied, application rate and mix details as required by Colorado law. No weed control program assumes that every single plant will be killed every year. As identified in the proposed weed management plan, different government entities classify weeds into many categories based on multiple factors. Colowyo, over the long-term, does an excellent job managing and controlling high priority weeds such as whitetop, leafy spurge, knapweeds, etc. Other priority weeds such as houndstongue, Canadian and musk thistle are more difficult to eliminate completely from year to year but are relatively easy to kill. These three weeds in particular are very adept at concealment (early and late) and creating multiple flushes of new plants during the spring, summer and fall depending on moisture conditions. Birds, elk, deer, antelope, rodents, the wind and vehicles are just a few of the many transportation avenues that promote new and continued weed infestations. Colowyo 's on-site weed management program is among the best in the state of Colorado and we spend on average over $20, 000.00 per year within the permit boundary on chemical and labor. Colowyo also spends between $40,000.00 and $50,000.00 in chemical costs alone outside the permit boundary on other owned/controlled land where leaseholders or Moffat County provide the labor. Some years are highly conducive to creating weed infestations; 2009 was one of those years with intermittent significant summer and fall rainfall events that caused several late season weed flushes. I ant supremely confident that Colowyo kills every weed it finds and treats on a year to year basis. We utilize the same individual every year to apply the herbicide, and we specifically target areas of stubborn infestation each year. A great deal of progress has been made, and Colowyo is committed to continuing this focus into the future. Colowyo will make a special commitment to address areas where cheatgrass has emerged as a continuing dominant plant community in mature reclamation areas. At least one test plot will be sprayed with Plateau or equivalent product during the fall of 2010. A test plot will also be sprayed on younger (1-3 year old) reclamation areas where cheatgrass is the only vegetation present. Colowyo will also treat these areas during the spring in 2011 and will interseed these areas in the fall of 2011 if success is achieved in knocking down the cheatgrass seed bank at these locations. Colowyo will provide the