GENERAL31441

• Permit No: C1981010
• IBM Index Class Name: General Documents
• Doc Date: 4/25/1986
• Doc Name: MEMO REVEGETATION STANDARDS
• From: MLRD
• To: GREGG SQUIRE AND MIKE LONG
• Permit Index Doc Type: VEGETATION
• Media Type: D
• Archive: No

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Richard D. Lamm
Governor
DATE:
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DEPARTMENT OF NATURAL RESOURCES
David H. Getcnes, Executive Director
MINED LAND RECLAMATION DI\
DAVID C. SHELTO N, Director
April 25, 1986
Gregg Squire and Mike Long
FROM: Mike Savage ~~
RE: TRAPPER MINE (C-81-010) REVEGETATION STANDARDS
I have completed n4' review of the information submitted by Trapper Mining
regarding shrub density standards, and cover and production standards in
response to revisions required by the Division during the mid-term review. My
concerns regarding Trapper's response are enumerated below.
Shrub Density
During the original review of Trapper's permit application, an agreement was
reached that Trapper Mining would reestablish shrubs (woody plants) on range
sites A and B utilizing mature shrub transplants and seeding (shrubs, grasses,
and forbs} in the areas between the mature shrub clumps. Average densities of
the mature shrub clumps (within the clump) were calculated to approach 14,000
stems/acre, which when averaged over the entire area disturbed yielded a
shrub-density near 650 stems/acre. This was calculated without counting
shrubs to be reestablished from seed between the clumps, which should
substantially increase the stem density over the disturbed area.
At this time, Trapper is proposing a woody plant density standard of 100
stems/acre which is inappropriate from the standpoint of our understanding
reached during the original review and from a consistent post-mining land use
perspective.
I would recommend that Trapper be held to the same woody plant density
standard established for other operators with similar conditions and the same
post-mining land uses and that the Division set the standard at 1000
stems/acres. This would also be consistent with the expectation of the
original review and approval.
Cover and Production
I am somewhat puzzled by Trapper's reply on these topics, since in RlY
memorandum of November 25, 1985 I virtually endorsed verbatim the "proposed
alternative" contained in correspondence to me from Mr. Wayne Sowards, dated
May 23, 1983. Several minor modifications to Mr. Sowards proposal were made
by me, which corrected typographical errors and assumptions. However, based
upon Trapper's submittal of "test case" data, I have reopened the review of
Trapper's proposal and found it to be inappropriate.
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. [phone]
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