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not reach the river as flows are absorbed "back" into the ground. Therefore, the contribution of this drainage to the Yampa River System is extremely insignificant. Currently Trapper has three drainages that ultimately contribute to the Williams Fork River. the closest, Elk Gulch (NPDES 010) is over one mile from the river with a storage capacity of 0.75 ac feet. Additionally, the discharge is normally less than 5 gpm (more of a trickle) and occurs for a very short time in the spring. It is unlikely that the discharge reaches the Williams Fork as the flows are absorbed "back" into the soil. Due to the distance away from the Yampa and Williams Fork Rivers, and the flow characteristics of the mine drainages, Trapper contributes very little to those rivers. We feel the requirement of a fish/fish habitat study is certainly not needed. Additionally, it seems logical if Trapper were expected to have an affect an these rivers, this would have been addressed during the initial permi! submittal and consultation period. NPDES permits place stringent specifications on Trapper discharge points, maintaining compli- ance with these standards prevents any contamination downstream, when flow conditions allow discharge. c. & d. The work done by Trapper Mining Inc. to date on wildlife invemories and' wildlife habitats is admirable. The Division requests the permittee.revise Tables 2.4-1 and 2,4-2 fo include an additional column of information that would identify within which of.ttie six habitazs described in Sectiop. 2.4.1 (sagebrush-grass, mountain shrub; cropland, pinon juniper, rocky barren areas; apd grass-shrub) each species prirnarily.resides. This would bring the perrniC mice into compliance with Rule 2.04.11(1); which iequires that "each application shall.include.a study.of fish arid wildlife and their habitazs .:." During the review of the fish and wildlife information, it was noticed that the majority of the information sources was published in the late 1970's and early 1980's:. The Division is in the' process of obtaining data tharis somewhat more recent; and pursuant Rule 2.04.11(3)(a), may require. the permit to be revised in the future to reflect any recent.changes in fish and wildlife levels, habitats, and T&fi species status. We will keep you appiised of this data-gathering. If Trapper Mining is aware of any studies, papers; articles, etc pub]ished afrer 19865 that would serve as a basis fo updating the TrapperMine permit to more:accurately address current.fish and wildlife levels and habitat conditions, we.would appreciate receiving copies of them.. Permit Section 2.3 describes the habitat types found within Trapper's permit area and adjacent areas. Section 2.4 discusses the wildlife resources within these same areas. We feel these sec- tions currently comply with Rule 2.04. / I (1) in that a detailed description of the habitat types are provided along with a list ajwildlife species that could be found in the same study area. Addi- tional breakdown of wildlife habitats would not provide any further useful information. Trapper Mine filed Technical Revision TR-48 which requested the discontinuance of the Big Game monitoring at Trapper. Positive support was received from the Colorado Division of Wildlife (See permit page 4-ISSd). The CDMG approved this revision, August /990. We feel this supports the success of our mitigation efforts concerning the effects of mining on wildlife. Since we are meeting the commitments of our permit as agreed by the CUMG and CDOW, addi- tional evaluation of wildlife resources is not required.