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• • III IIIIIIIIIIIII III <br />999 <br />STATE OF COLOI~UO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1 3U Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: 130]1 866-3567 <br />FAX: U01)872-8106 <br />May 9, 1997 <br />Mr. Forrest Luke <br />Environmental Manager <br />Trapper Mine <br />P.O. Box 187 <br />Craig, Colorado 81626 <br />Re: Technical Revision No. 71, Bond Release Plan Changes, Trapper Mine, <br />Permit No. C-81-010, Trapper Mining Inc. <br />Deaz Mr. Luke: <br />I~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. Lochhead <br />Executive Director <br />Michael 8. Long <br />Division Director <br />The Division has completed its review of TR-71 and has the following general comments <br />and specific questions: <br />General Comments <br />The permit contains a success standazd for cover which is derived by back- <br />calculating the amount of cover required to hold erosion to an amount which the <br />NRCS says is acceptable for the soils disturbed by the mine. The Division has two <br />concerns with these standards. <br />A. This means of establishing revegetation success standards is referred to as <br />"technical standazds" in the regulations. The Division is only allowed to <br />approve technical standards in conjunction with OSM approval, which was <br />not done in the case of the standards in the Trapper permit. The Division is <br />presently in the preliminary stages of arule-making effort in which <br />allowance will be made for the Division to approve technical standards. In <br />the mean time, there is no regulatory basis for the cover standards in the <br />Trapper permit. <br />B. The live vegetative cover standards for range sites A, B and C are 33%, <br />29%, and 25%, respectively. These values are relatively low in comparison <br />