Laserfiche WebLink
iii iiiiiiiiii~« iii <br />999 <br />TRAPPER NININC INC. <br />May 29, 1996 <br />RECEIVED <br />Mr. Joseph J. Dudash JUG O <br />Enviromnental Protection Specialist 3 1996 <br />Colorado Division of Minerals & Geology <br />1313 Sherman Street, Room 215 Division of Minerals & Geology <br />Denver, CO 80203 <br />Dear Joe: <br />Re: Trapper Mining Jnc., Permit No. C-81-O10, MR-147 <br />Revision to Conceptual Rangeland Bond Release Plan <br />Enclosed please find a revised Section 4.4 to the above-referenced permit. This revised section is intended <br />to replace the existing section th the permit document. Also enclosed are applicable page updates to the <br />Table of Contents and a Cross Reference Index to changes resulting from this revision. Note that the pro- <br />posed section 4.4 has been completely repaginated. <br />A good portion of the revision is concered primarily with housekeeping--updating field monitoring <br />approaches and deleting irrelevant and outdated information. The substantive changes are addressed in <br />more detail below. <br />References to range condition and trend were deleted. These concepts aze relative measures of cur- <br />rent rangeland health and the direction rangeland health is heading. Neither concept really applies to <br />reclaimed landscapes. Moreover, range condition has essentially fallen out of favor as a rangeland <br />concept among range management professionals th recent years. <br />2. The sampling methodology and statistical testing approach for cover, production and shrub density <br />sampling was rewritten in line with CDMG's GUIDELINE REGARDING SELECTED COAL MINE <br />BOND RELEASE ISSUES, dated April 18, 1995. Much of the extraneous narrative included with <br />these discussions was removed and the overall approach was made more general to allow for added <br />sampling flexibility. An exception to the more general sample approach was that a detailed discus- <br />sion on the cover and production component provided by noxious and annuaVbiennial weeds was <br />added to define the restrictions on counting these plant species. <br />3. The plant diversity standard was revised from a comparison of reclaimed plant community species <br />composition against premining plant community species composition to a technical standard that <br />reflects objective measurements of desired postmining plant community species diversity goals. This <br />proposal is th line with the approach taken by most other coal wmpanies in the state and allows <br />Trapper to eliminate reference area sampling. As a result, discussions on reference azeas have been <br />eliminated with this revision. <br />4. The stem density standard for shrb clumps was revised to include an allowance that any shrubs <br />counted above the 400 stems/acre overall shrub density standard be allowed to count as an offset to <br />any shrub density shortfall that might occur within shrub clumps. This proposed change in the shrub <br />P.O. Box 187 Craig, Colorado 81626 (303) 824-4401 <br />