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Ms.Robin Reilley,DRMS <br /> Re: Trapper SL-20 <br /> Response to DRMS Comments <br /> Page 2 <br /> Tramper Response <br /> o See the response to the first bullet point above. <br /> o The incorrect density unit on Table 5 has been corrected and is attached. <br /> DRMS Comment <br /> Rule 4.15.8(5) Revegetation Success Criteria <br /> 1. The diversity standard requires that one perennial forb have at <br /> least 3% cover. The Plant Cover Table 3 shows that Medicago <br /> sativa was the species with the greatest cover value of 2,48%. <br /> This parameter of the diversity standard has not been <br /> satisfied. <br /> Under the circumstances, DBMS could not make a finding that TMI <br /> met the vegetation diversity standard as stated in the rule. <br /> Trapper Response <br /> Trapper makes the following arguments in support of our contention that the diversity <br /> standard was met. <br /> We have previously rounded up to 3% in <br /> Phase III bond release applications when applying the 3% standard for grasses <br /> and forbs and feel it is appropriate to continue to do so. In this case a 2.5% value <br /> is rounded up to 3%. <br /> 2. This is particularly appropriate when <br /> considering that we received virtually no rain during the summer of 2018. It was <br /> one of the driest summers on record and forb species in particular were <br /> negatively impacted. The forb diversity standard was easily met in a relatively dry <br /> 2017. <br /> 3• Our vegetation sampling contractor, Kent <br /> Crofts, noting that forb cover was very limited in this 2018 drought year, took the <br /> extra step of separating Medicago Sativa (alfalfa) production from production clip <br /> plots and was able to demonstrate that this forb species made up 15.5% of all <br /> plant production in 2018 (Table 4). Given that plant cover measurements are <br /> used as a predictor of plant production, it is obvious that alfalfa was a significant <br /> contributor to overall plant diversity in 2018. <br /> Please contact me if you have any questions or concerns regarding this <br /> correspondence. <br /> Sincerely, <br /> Forrest Luke <br /> Environmental Manager <br /> [SL-20 Response 1.doc] <br /> End <br /> c File 109.2.3.3 <br /> SL-20 notebook <br />