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Mr. Humphries - 4 - February 9, 1987 The Division firmly believes that a standard of 1,000 stems of woody plants per acre is technics~lly justifiable. Item 3) What is the basis for the Division's imposing a shrub standard different from what was originally proposed and approved? Rule 2.08.3 requires that the Division conduct a review of each permit issued, prior to its mid-term (2 1/2 years). Based on this review, for good cause shown, the Division may require reasonable revision or modifications of the permit provisions to ensure compliance with the Act and Regulations. Good cause in this case includes: a. At the present time it is not clear if there is a shrub density standard for the Trapper mine. A standard is required by 4.15.7 and 4.15.8. Until it is clear that an approved standard has been established the Division cannot ensure that compliance with the Act and Regulations is being met. Mike Savage, vegetation specialist for MLRD has stated in a memo and verbally that Trapper Mining's shrub clump methodology as proposed in the permit application, and in the associated Appendix E, would provide approximately 650 stems per acre over the entire site and that additional shrubs provided by inter-clump seeding would bring this count to approximately 1,000 shrub stems per acre. This estimate seems reasonable if it is assumed that the shrub clumps would be planted with a shrub density close to that of the pre-existing density on Range Site A where most of the clump transplants would come from. This density is 34,561 stems per acre (Table 2.3-9, Permit Application). If 1.6 acre clumps are planted at 34,561 stems/acre 55,298 stems would be established, divided by the 46 acre area of influence there would be 1,202 stems/acre without additional inter-clump seeding. However, actual shrub clump densities are not approaching the estimated densities. Actual counts are averaging about 5,250 stems per clump or 3,280 stems/acre in the clump areas. These numbers yield only 114 stems (shrubs per acre), far below the assumptions made at the time of the permit approval. Therefore, the Division maintains that there is a problem in that the originally assumed shrub reestablishment goals are not being met. c. As discussed under Item 2. Section e), the Colorado Division of Wildlife is to be consulted in matters of wildlife mitigation. The DOW has recommended a shrub density standard of 1,000 stems per acre on areas classified as mountain shrub vegetation. Since this standard has not been proposed or approved the Division believes that there is "good cause" to reopen this issue.