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'.~ • TBflPPER ~II ~I~~~~~I~~~~~~I~ INC. - August 10, 1989 ~~~~~~~ CERTIFIED #P175046591 Mr. Tony Waldron Colorado Mined Land Reclamation Division MINED Lan ~ 215 Centennial Bldg. RECLAMATION DIVISION 1313 Sherman St. Denver, CO 80203 Dear Tony: Subject: Technical Revision TR-46. Topsoil Seeding Exclusion in the 1989 Derringer Pit Replacement Area. Trapper Mine proposes to exclude drill seeding, with our approved seed mix, on the 1989 Derringer Pit topsoil replacement area. The area is comprised of 18 acres of range site A, 29 acres of range site B, and 9 acres of range site C (total 56 acres - see attached map). The motivation behind this proposal stems from no-seed plots (approx four acres each in size) established in 1985 in both Derringer and Enfield pits. The results of this study indicate herbaceous canopy cover to be similar on non-seeded versus adjacent seeded plots established during the same reclaim year. Additionally, woody stem densities were higher and perennial plant production lower on non-seeded reclaim areas when compared to seeded areas. Perennial plant species comprised 708 of the species composition on both reclamation treatments (seeded and non-seeded). (See attached interoffice correspondence H.B. Humphries and W. Agnew for additional analysis of the postmine no-seed study.) Due to the limited size of the initial no-seed areas, a larger establishment plot (1989 D pit reclaim) is necessary to verify the results. Topsoiling of the proposed area is complete and was accomplished entirely through live-haul material transport. The area currently provides approximately six percent litter cover from live-haul woody debris and four percent rock cover. Vegeta- tion sampling methods will be followed as described in the attached correspon- dence with permanent transects established in each range site. Appropriate remedial action will be taken to control the invasion of noxious weeds, if necessary, as outlined in our current mining and reclamation permit. Appro- priate conservation practices will be performed on the area just as is per- formed on seeded areas (e. g. topsoil dragging, diversion ditch establishment, etc.) Trapper realizes the establishment of this plot does not allow any exception from meeting the reclamation requirements outlined in Section 4.15 P.O. Box 187 Craig, Colorado 81626 (303) 624-4401