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LOUKONEN BROS. <br />STONE COMPANY <br />12993 N. Foothills Hwy. Longmont, CO 80503 <br />Phone: (303) 823-6268 FaK. (303) 823-W3 <br />Applications were made primarily in the spring during rapid growth, in the fall prior to and <br />during knapweed bolting and occasionally during the middle of summer. Such applications <br />were made based on the most current and commonly accepted practices recommended on <br />label for the respective chemicals being used. I have no other proof of application other than <br />having the sprayer, stored containers of herbicides and empty herbicide containers. Invoices <br />and old paper records are disposed of every couple of years. <br />Thousands of dollars and many man hours went into the weed control effort. Suppression of <br />the knapweed was achieved up to two years ago until, it is assumed, highly favorable growing <br />conditions and the huge influx of knapweed seed from sources outside the quarry, caused the <br />knapweed population to explode. <br />Section 3.1.10 (6) simply states: "Methods of weed control shall be employed for all prohibited <br />noxious weed species, and whenever invasion of a reclaimed area by other weed species <br />seriously threatens the continued development of the desired vegetation." As stated in the <br />foregoing paragraphs, Loukonen Bros Stone, as the Operator did observe and comply with this <br />requirement through timely on-label applications of recommended herbicides at the optimal, <br />recommended best stages of plant growth for chemical assimilation as part of the yearly on- <br />going management plan of the quarry. As such, the management plan is not a written <br />document for the company but a routine process that is adjusted as needed year to year. <br />Though not apparent to a cursory inspection, a weed control plan did exist and control efforts <br />were made and were successful until recent conditions favored huge increases in the knapweed <br />population. It is very difficult, if not impossible, to achieve even suppression, let alone control <br />of noxious weeds if there are vast pools of uncontrolled noxious weeds surrounding our quarry. <br />Thus, I have explained and expounded upon our past course of action to control noxious weeds. <br />I will attach a brief outline of that plan of action as applied in the past and planned for the <br />future with added record keeping retention emphasis to provide proof of performance. I have <br />a degree in range ecology and retired from the USDA NRCS after many years of administering <br />CRP grass planting and weed control programs in eastern Colorado. I hope you will believe and <br />agree with the information you have been given and find Operator resources and capability <br />adequate to address the weed control issue. <br />However, if you disagree and doubt the Operator's honesty and capability to handle weed <br />control-and-direct-corrective-action-regt?ir-ing-the-weed-c-orrtrol--plan-to-be submitted-as a- <br />Technical Revision requiring a revision fee, please advise of operator appeal rights and <br />procedure. Thank you for you time and consideration of this corrective action response. <br />e ec ully, <br />L. Dean L ukonen, President - Loukonen Bros Stone <br />Michael Loukonen, Vice President - Loukonen Bros Stone