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Mr. Larry Routten, CMLRD <br />May 31, 1991 -page 2 <br />Section 7.1 -Vegetation Monitoring for Seeding Exclusion in 1989 Derringer Pit Topsoil Area <br />As requested, Trapper will continue vegetation monitoring and reporting on the Derringer pit seeding <br />exclusion area. <br />Section 7.2 -Proposal by Trapper Mine to Exclude Drill Seeding of Approved Grass Species in our 1991 <br />Derringer Pit Topsoil Replacement Area <br />1) To answer the Division's question "Why are woody plants not proposed for seeding in range site C?" <br />Answer: Trapper's range site C mix does not include woody plant materials in the approved seed mix <br />and never has included woody plants. This proposal was an attempt to evaluate natural woody plant <br />establishment via livehaul transport, without competition from seeded grasses. <br />2) Trapper wncurs with the Division's recommendation that three different methods of vegetation <br />establishment, beginning at the same time could provide a more meaningful assessment and compari- <br />son of vegetation establishment techniques. Trapper requests Division approval for the following <br />seeding proposal in Derringer pit during 1991 (see attached schematic): <br />a) 16-acre plot excluding grasses from our approved range site A mix. <br />b) 15-acre no-seed plot <br />c) 15-acre plot drilling our approved range site B seed mix <br />d) 6-acre plot drilled with our approved range site C seed mix. <br />3) Trapper will commit to re-seeding with proven establishment methods all field trial areas that deviate <br />from our proven approved establishment criteria in the event the trial fails. <br />4) No revised permit pages were submitted. <br />Section 7.3 -Proposal to Reduce Allowable Topsoil Amounts on Reclaimed Rangeland Areas <br />1) Trapper concurs with the Division that plant species diversity is not a problem at Trapper Mine. <br />Trapper never suggested plant species diversity was a problem on the mine site. Rather the Redente <br />report supported a case for more diverse plant communities with shallower topsoil depths. <br />2) Trapper has updated page 4-256 of our mining and reclamation permit to clarify the extent that top- <br />soil replacement depths can vary on rangeland areas. <br />3) Smooth brome has not been used in any of Trapper's approved seed mixes for several years. <br />4) Trapper strongly supports the conclusion and validity of the Redente study. The area in which the <br />study was conducted is very representative of the dominant soils, slope,exposure and vegetation at <br />Trapper Mine. Obviously, when setting up a study, as this was 11 years age, the inferences made from <br />sampling results may not be totally applicable in all areas or situation. However, to say future corre- <br />lations of these results with another area may not be valid is a fairly bold assumption by the Division. <br />This is the best study Trapper and the Division has evaluating soil-vegetation correlation on a site <br />specific basis at Trapper Mine. <br />Trapper's intentions to utilize a reduced topsoil replacement criteria as proposed in our 1990 Annual <br />Report may have been somewhat misinterpreted by the Division. In no fashion would Trapper inten- <br />tionallymisuse or abuse a general statement within our permit document. In all cases, Trapper would <br />first consult with the Division and receive appropriate approval prior to implementing any field study, <br />experimental practice or other practice that deviates from our Proven approved techniques. We in <br />the mining industry, both mine operators and regulators, are still seeking the optimum solutions to <br />the reclamation challenge. Our combined insight and implementation of new and proven practices <br />and techniques is [he future of our industry. By incorporating site specific data collection information <br />