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<br /> <br />Mr, Bill Agnew - 4 - May 20, 1991 <br />2, Trapper did not provide enough detail in this proposal about how many <br />"smell areas" they intend to establish, and where exactly they would <br />establish them, We cannot approve a plan that deviates from topsoil <br />replacement requirements without knowing the exact areal extent. <br />3, There are several areas in the study by Re dente where inferences or <br />conclusions are drawn which may not be completely supported or apply to <br />the current situation at Trapper, For instance, smooth brome grass <br />(Bromus inermis? is the grass with the greatest representation in the <br />test plots. This species of grass is known for its aggressive, <br />competitive nature, and probably influenced the establishment of fortis <br />and shrubs in the test plots. Current seed mixes generally contain a <br />much smaller amount of smooth brome due to this very fact. <br />4. We assume that the majority of reclamation left to be performed is in a <br />more upland oak brush type environment, where there is more moisture and <br />generally a northern exposure. This study was conducted in a flatter, <br />dryer, area with sagebrush as the dominant woody plant. Attempting to <br />correlate the resul is of this area with what one mi ght expect in a <br />different area may not be valid, <br />We must recommend that this Droposal, as presented, be denied at this time. <br />Trapper may want to consider implementing one or two areas of thinner topsoil, <br />as afield trial provided for under Rule 4.15.6. <br />Section 7.4 - A.O.C. Determination <br />1, The drainage channel profiles shown on Map M-14 indicate that channel <br />reconstruction is occurring in compliance with the approved plan. <br />2, The post mining Drofiles appear to indicate reclamation grading which <br />approximates the approved post mining topography. This is based upon the <br />assumption that the dotted line representing "post-mining topographic <br />profile" is an accurate depiction of the approved post mining topography. <br />3, Please submit copies of the four maps included with this section, which <br />are signed by your professional engineer. <br />4. A detailed analysis of A.O.C. achievement will be conducted at the <br />time of Phase I Bond Release. <br />Section 7,5 -Grazing of Reclaimed Land <br />Rule 4,15.5 does allow for grazing of reclaimed lands by domestic livestock. <br />We see no major problem with this Droposal, and it seems to be supported by <br />other experts in the range science field. Trapper should commit to updating <br />the Division on the progress of the grazing plan and report the results in <br />their annual report. <br />