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COLORADO <br />Division of Redamati , <br />Mining and Safety <br />QCpyrtr"eri[ -�l Na«u=a; kg <br />Forrest Luke <br />Trapper Mining, Inc <br />P.O. Box 187 <br />Craig, CO 81626 <br />2 July 2020 <br />Re: Trapper Mining, Inc., Permit C1981010 <br />Forb Standard Recommendations <br />Dear Mr. Luke, <br />Having discussed the topic of TMI's cover standard with respect to the forb component with DRMS <br />staff specializing in vegetation and vegetation standards, please consider the following guidance in <br />your process. <br />DRMS finds that vegetation sampling at Trapper Mine has in some instances taken place late in the <br />growing season after many forbs have completed their life cycle. Although Trapper's current <br />standard is rather narrow, Trapper generally meets that standard. Therefore, in contemplating an <br />update, Trapper may wish to consider broadening the standard to include various forb species, rather <br />than relying on just one species to meet the 3% mark, thereby addressing the overall goal of <br />vegetative diversity. Also, because the current standard is usually met, Trapper may wish to consider <br />incorporating a second option from which to choose, similar to what was effectuated in Technical <br />Revision TR124. This option could incorporate multiple forb species and life forms with the caveat <br />that no one species would dominate. <br />As with any standard, its development should be data driven. A result of the PR7 process was the <br />collection of current baseline data, this, and the original premine dataset as well as Trappers long <br />history of bond release data provide a rich collection of information. Certainly, looking at recent <br />baseline data and possibly the last three or so sampling events would elucidate trends on which to <br />base a proposal on. <br />I'm available to answer any additional questions that come up. <br />Best Regards <br />Robin Reilley M.S. GISP <br />Environmental Protection Specialist II <br />303.866.3567 ext 8105 <br />Robin.reilleykstate.co.us <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us I :V <br />*' ri lt� <br />. ti <br />Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director <br />ams <br />