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"List C weed species are species for which the Commissioner, in <br />consultation with the state noxious weed advisory committee, local <br />governments, and other interested parties, will develop and implement state <br />noxious weed management plans designed to support the efforts of local <br />governing bodies to facilitate more effective integrated weed management <br />on private and public lands. The goal of such plans will not be to stop the <br />continued spread of these species but to provide additional education, <br />research, and biological control resources to jurisdictions that choose to <br />require management of List C species. " <br />This goal has been implemented in the Keenesburg Mine reclamation plan. <br />With regard to annual and biennial forbs that the Division has elected to deduct from the <br />total vegetation cover during consideration for bond release success, CEC observes that <br />many of these species are either native to the area, considered naturalized, or have been <br />used for decades as reclamation species. Native annual species found during the Phase II <br />vegetation sampling include; Amaranthus retroflexus, Erigeron speciosus, Eriogonum <br />annuum, Helianthus annuus, Lactuca serriola, Lepidium densiflorum, and Plantago <br />patigonica. The single biennial species encountered in sampling was Melilotus <br />officinalis, hardly a detriment to revegetation success, as this species has been used for <br />decades as a stabilizing, nitrogen fixing plant. <br />Again, CEC requests clarification from the Division for deducting annual and biennial <br />species from consideration in the total vegetation cover revegetation success evaluation <br />of the Phase II bond release at the Keenesburg Mine. <br />If the implementation of this procedure is a new policy by the Division, as we have not <br />encountered this procedure in prior bond release requests, CEC would ask to be provided <br />with the source documentation which empowers this application. <br />Should you wish to discuss these issues prior to responding, or need additional <br />information from us, please contact us at your convenience. <br />Sincerely, <br />Cc: Savage & Savage <br />Manager, Energy Services