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Hernandez, Alysha <br />From: Brown, Sandy <br />Sent: Friday, September 23, 2011 4:26 PM <br />To: Hernandez, Alysha <br />Subject: FW: SL12 Question <br />Attachments: 2006 ARR - Exhibit 2006 -14 Interseeding.pdf <br />Alysha, <br />Will you please put a copy of this email in laserfiche? Permit No. C- 1981 -008, SL12. <br />Thanks, <br />SB <br />From: Brown, Sandy <br />Sent: Friday, September 23, 20114:15 PM <br />To: Ross Gubka <br />Cc: Talvitie, Marcia <br />Subject: SL12 Question <br />Hello Ross, <br />I'm back working on the SL12. I was also looking at past Annual Reclamation Reports because you refer to them in your <br />July 6, 2011 letter and they also support the bond release application. Exhibit 2007 -9, 2007 Fertilizer Distribution and <br />Soil Sample Map, shows that 15.54 acres of the dryland pasture requested for bond release in SL12 was interseeded. <br />Looking back at the 2006 ARR Exhibit 14 shows that 23 acres of dryland pasture and 36.4 acres of irrigated pasture were <br />interseeded that year. In contrast, the SL12 application specifically says for both Irrigated Pasture and Dryland Pasture, <br />"interseeding did not take place ". Unless there are specific provisions in the approved permit, interseeding is not <br />allowed. I did not find provisions allowing interseeding in the permit as it was approved with Technical Revision No. 58. <br />Perhaps you are aware of something I did not find. If so, please let me know. Otherwise, parcels interseeded in 2006 will <br />not be eligible for Phase III bond release. <br />This review is based on Rule 4.15.7(5) which lists the approved husbandry practices for reclaimed areas. 4.15.7(5)(g) <br />allows interseeding on rangeland /wildlife habitat during the first four years of the 10 -year liability period, upon approval <br />by the Division. Allowed husbandry practices discussed and approved with TR -58 include irrigation, fertilization, rill and <br />gully management and weed and pest control. There is a mention of reseeding on page 2.05.4(2)(e) -9, however no <br />details are provided and no interseeding plans were approved by the Division. <br />Please call if you have further questions. <br />Sandy <br />Sandra L. Brown <br />Senior Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />303 - 866 -3567 x 8110 <br />