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~~ -~ • • - III IIIIIIIIIIIIIIII <br />~~~~~ STATE OF COLORADO <br />Roy Romer, Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />MINED LAND RECLAMATION DIVISION <br />DAVID C- SHELTON, Dlreetor <br />February 9, 1987 <br />Mr. H. Bruce Humphries <br />Trapper Mining, Inc. <br />P.O. Box 187 <br />Craig, Colorado 81626 <br />Re: Mid-Term Review Responses - Shrub Density Standards - File No. C-81-010 <br />Dear Mr. Humphries: <br />The Division has received your correspondence of December 17, 1986 (Mid-Term <br />Review Shrub Density Standard for Range Sites A and R). A review of this <br />material shows that.you have addressed three issues: <br />1. What is the shrub density standard approved by the Division in the <br />original permit application? <br />2. Is the Division's standard of 1,000 stems per acre technically <br />justifiable at Trapper Mine and consistent with the approved post-mining <br />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 />The Division's responses to these issues follows: <br />Item 1) What is the shrub density standard approved by the Division in the <br />original permit application? <br />As stated in the Trapper Mine Proposed Decision Findings of Compliance, <br />November 23, 1982, under Section XII Vegetation, "The Division has reviewed <br />the supporting information provided and has approved the proposed plan. The <br />plan involves the transplanting of mature shrub changes of a given size onto <br />the reclaimed surface." The findings document makes no mention of a stem <br />count density standard. <br />As stated in the mid-term review, the permit application on page 3-117a states <br />that "No actual shrub stem or plant density is proposed as a reclamation <br />standard." <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567 <br />