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Saecific Ouestions <br />Trapper proposes to apply any stem counts in excess of 400/acre (the overall <br />success standard) to the stem counts within shrub clumps, where the success <br />standard is 3674 stems/acre. No reason is given for this suggested change. Please <br />explain why the Division approved standard should be changed. <br />2. On page 4-119, Trapper proposes to estimate shrub density within shrub islands by <br />means of direct count belt transects "or comparable techniques." Alternate <br />sampling techniques should either be described in the permit, or the reference to <br />"comparable techniques" should be deleted. <br />A new diversity standard is proposed. While the proposed standard appears <br />reasonable, there is no explanation of how it was derived, or what it is based on. <br />Please explain the basis for the proposed diversity standard. <br />4. Trapper proposes to drop the use of all established vegetation reference areas since <br />standards for cover, production, woody stem density and species diversity will all <br />be set in the permit. However, because there is no regulatory basis for the cover <br />standard (see no.l in "General Comments"), the Division believes that the <br />approved reference areas should be kept in place, until that time when the <br />regulations can be changed to allow Division approved technical standards. <br />The Division is interested in receiving Trapper's ideas on the above general comments, as <br />well as the specific questions. If you have any questions, please call me. <br />Sincerely, <br />(`~ <br />V <br />seph J. Dudash <br />Environmental Protection Specialist <br />C:\W P61 \TRAPPER\TR71 ADEQ <br />