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• be counted in the clumps. These clump area species must be those which will meet the intent of the proposed land use, providing thermal cover and hiding areas for dear and elk. b. Productivity and Cover Standards - The applicant, in the permit application, proposed using a linear regression method of determining revegetation success standards for cover and production. The Division determined that such a method was inappropriate, therefore, Stipulation 1 was included in the permit document requiring the applicant and the Division to devise acceptable criteria for the evaluation of revegetation success for herbaceous cover and productivity. •- Trapper Mining has submitted an alternative method, which, with some modifications, will be acceptable to the Division. These modifications are outlined in the attached memo from M.S. Savage to Gregg Squire (November 15, 1985). Since this issue appears to be nearly resolved, an acceptable revision to the permit should be submitted to the Division as soon as possible to satisfy the requirements of Stipulation 1. 3. R ill and Gully Plan - Trapper's rill and gully plan is found in Section 3.6.3.6 of the permit application and was also approveo as a T.R. to the permit in 19&4. However, based on current Division policy this revision is now unacceptable for the following reasons: o Delay of rill and gully repair for three growing seasons creates a situation where severe erosion could occur for three years without being abated. The operator's only responsibility within that period is maintenance of contour furrows and ditches. This practice is not in compliance with current Division policy or Rule 4.14.6(1). o The current plan includes choosing permanent gullies from those gullies existing after the three-year waiting period. This clearly does not comply with the Division policy on permanent gully formation, which states that the location of permanent gullies must be identified before gully formation. Further, certain demonstrations m~be made to allow for the inclusion of permanent gullies in the plan. Based on these findings, the Division wil] require Trapper Mining to submit a revised rill and gully stabilization plan. This plan must include: o Inspection frequency for checking rill and gully status. o Procedure for backfilling and grading all rills and gullies greater than 9 inches and all other excessive erosion as defined in the Division's policy paper of May 2, 1985. The procedure should include measures to minimize disturbance to existing vegetation. o A timetable for implementing both permanent and temporary stabilization methods. This timetable should provide for backfilling and grading as soon after detection as field conditions permit.