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't Mr. Gregg Squire 2 December 17, 1986 Colorado Mined Land Recl. Division Following is a discussion uf. each issue: Issue 1. What is the shrub density standard approved by the Division in the original permit application? We du not believe that the Division uverluoked such an important issue as shrub density in the initial permit approval. Rather we suspect, as with us, that the approved standard was uverluoked in the mid-term review, Significant portions of the original application concerning pre and postmine vegetation, land use, wildlife habitat and mitigation, and reclamation dealt specifically with whether or not shrubs should be reestablished and at what densities. Appendix 0 of the permit application contains a lengthy analysis of shrub reestablishment as it pertains to improving wildlife habitat and use. An overall shrub stem density of 400 stems per acre was presented in Table 4 of Appendix 0. Of that total, around 81 stems per acre were to come from mature shrub transplants. The remaining 319 stems per acre were contemplated to be established through seeding, small transplants, volunteer, etc. In Mr. Savage's memo, he states Chat, "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." We have reviewed the permit application and all past c~rrespon- dence which we know about, and can find nu reference to those numbers ur basis for their calculation. Even if one assumes the 22,400 stems per clump (14,000 stems/acre x 1.6 acres per clump) is correct, when that total is divided by the approved area of influence, spacing between clumps, i.e. 46 acres, the density is only 487 stems per acre. This still is far short uE the 650 stems per acre in the memo. Moreover, it provides nu retional basis fur Mr. Squire's recommendation Cu change the standard to 1000 stems per acre. Issue 2. Is the Division's standard of 1,000 stems per acre technically iustif.iable at Trapper Mine and consistent with the approved postminiR land use? A review of literature available to Trapper Mine strongly suggests that 1,000 stems per acre is an excessively high density standard Eur shrubs because it would eliminate [he rangeland element of the approved pus [mining land use. One thousand stems per acre at bond release will involve very young shrubs, in early ,[ages of development, particularly Erum seeding areas between clumps. .4s these individual plants mature and initiate sproutin,e and propagation via seed, their stem densities iaili increase. cont.