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J., i <br />'' ~ ~iiiiiiiiiiiiiiiiiii <br />TRAPPER MINING INC. <br />December 17, 1986 <br />CF,RTIFIED >kp297324722 <br />Mr. Gregg Squire <br />Colorado Mined Land Reclamation Division <br />423 Centennial Building <br />1313 Sherman Street <br />Denver, CO 80203 <br />Dear Gregg: <br />~~~~~~~® <br />DEC 1J 1986 <br />MINED LAND <br />~:1tCLAMATiON DIVISION <br />Re: Mid-term Review Shrub Density Standard for Range Sites A and B. <br />In correspondence dated ,Tuly 8, 1986 Current Status of Trapper Mine's Mid- <br />term Review Issues), you stated that the Division does not concur in Trapper's <br />proposal of 100 stems/acre. Also, in the April 25, 1986, memorandum from Mr. <br />Mike Savage to you and Mr. Mike Long, Mr. Savage stated that the original <br />permit reflects an agreement on an average shrub stem density of 650 stems per <br />acre through shrub clumps alone. He further mentioned that seeding should <br />increase the stem densities. Because of Trapper's 100 stem per acre proposal, <br />he recommended a standard of 1000 stems per acre was consistent with the <br />original review and approval.. <br />Our further review of the record of. the original permit application review <br />indicates that both Trapper and the Division have been in error in their eval- <br />uation of this issue during the mid-term review. Trapper assumed that the <br />permit has no stem density standard and the Division assumed is was 650 stems <br />per acre. In fact, the currently approved permit does contain a shrub density <br />standard of 400 stems per acre fur Range sites A and B. Approximately 81 of <br />the 400 stems per acre are to come from live shrub stems within mature shrub <br />clumps. Also, as discussed in the following narrative, we feel that standard <br />(400 stems/acre) remains appropriate for Che pos[mining land use designated <br />fur reclaimed Range Sites A and B. <br />In resolution of the stem density issue, several sub-issues must first be <br />addressed. They are as Follows: <br />1. What is the shrub density standard approved by the Division in the ori~i- <br />nal permit application? <br />2. Ls the Division's standard of L,000 stems per acre technically iustifiable <br />at Trapper Mine and consistent with the approved postmining land use? <br />3. What is the basis for the Division's imposing a shrub standard different <br />from what was originally proposed and approved? <br />cunt. <br />P.0. Box 187 Craig, Colorado 81626 l3t)31 824-4401 <br />