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Mr. Mike Boulay -2- March 23, 2011 <br />SCC: Permit pages 14-18 through 14-21 have been amended and are <br />enclosed. <br />C. Explain the procedure used to combine all reclaimed areas, being <br />compared to the Greasewood/Shadscale reference areas, into a single <br />combined unit. <br />SCC: The two separate areas at Snowcap (those compared to the Greasewood <br />Reference Area vs. those compared to the Shadscale Reference Area) <br />will not be combined into a single unit for weighting and testing. Because <br />of the systematic sampling program, weighting will occur "naturally" for <br />the two circumstances of reclamation as a result of the procedure. <br />"Sampling Methodology" found on new appendix page A14-11-4, submitted with <br />the original application, more fully explains the sampling procedure to be used <br />and current permit pages 14-25 and 14-26 describes how the reclaimed areas <br />will be delineated for comparison to either the Greasewood or Shadschale <br />Reference Areas. <br />3. DRMS: The cheatgrass in the North Decline Area was treated with Plateau <br />(2005 & 2006) and the area was hydro-seeded in early 2007. In a February 14, 2005 <br />letter (attached), Dan Mathews (CDRMS) said county weed supervisors and BASF <br />(Plateau herbicide) technical support (names and numbers listed) were contacted for <br />guidance on cheatgrass control before the North Decline Area treatment. The issue <br />about contacting area weed district supervisors was raised again in a 2009 letter from <br />CDRMS to J. E. Stover & Associates. Were these authorities contacted after the 2005- <br />07 treatment with current results for a follow-up consultation? Please include any follow- <br />up consultations, discussions or correspondence in regard to this matter. <br />SCC: Dan Mathews, DRMS, and Tonya Hammond, J. E. Stover & Associates, <br />Inc., met with Dr. George Beck, Extension Weed Specialist from the Colorado State <br />University, in Grand Junction on December 9, 2009. Dr. Beck had been contacted by <br />DRMS to conduct a literature review for them on cheatgrass with the possibility of <br />conducting field studies at local coal mines that were having problems. We had hoped <br />to tour the reclaimed sites at Snowcap Coal, but snow accumulations prevented us from <br />going on site. We did have a chance to discuss with Dr. Beck the control measures that <br />Snowcap had performed at the North Decline (herbicide treatment and interseeding) <br />from 2005 to 2007. This control measure garnered no noticeable, new establishment of <br />seeded species and within a couple of years the presence of cheatgrass was as <br />prevalent as prior to treatment. Dr. Beck had no further suggestions for us at that time. <br />On February 10, 2010, another meeting was held with Dan Mathews and Mike Boulay, <br />DRMS, Tonya Hammond and Jim Stover, J.E. Stover & Associates, and Steve Viert, <br />Cedar Creek Associates. We discussed the 2005 to 2007 cheatgrass treatment and the <br />disappointing results that had been achieved. We also discussed how there had been <br />no improvement at CRDA #1 after interseeding was done in September 2001 on <br />benches 1, 2, 3 and portion of 4. It was decided in this meeting that sampling would be <br />performed on the areas seeded in 2002 or before, including extra transects on areas <br />adjacent to reclaimed areas in order to document the abundance of cheatgrass on <br />undisturbed lands. Upon receiving the 2010 Revegetation Evaluation is was decided