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DATE: April 30, 1991 <br />T0: David Berr/y~ <br />FROM: Carl Mount( ",. Q <br />RE: Reference Area Spraying, Trapper Mining, Inc., <br />Trapper Mine, Permit No. C-81-010 <br />I have reviewed the informational letter that Trapper Mining, Inc. (TMI) sent <br />regarding the coal fire and vegetation reference area spraying. It appears <br />that TMI does not have management control over the two particular reference <br />areas that were sprayed. When Utah International, Inc. owned the Trapper <br />Mine, they may have had control over all reference areas. At any rate, I <br />cannot find anything under Rule 4.15.7(3) which would require an operator to <br />maintain control over the vegetation reference areas. Rule 4,15.7(3)(d) and <br />(f) do have some bearing on the matter as they require the reference area to <br />be ". managed in a manner which is in accordance with the approved <br />post-mining land use..." and for the reference and vegetated areas to receive <br />the same management for the last two full years of the extended liability <br />period. Neither of these rules directly applies to the matter of herbicide <br />spraying since it is an accepted brush and forb control practice on rangeland <br />and I don't believe TMI is applying for any Phase II bond release in the next <br />two years on any of their disturbed langs. <br />In order to solve the problem and maintain both ou <br />should require them to establish two more reference <br />vegetation type) that are statistically similar to <br />type that they have left. This may encourage them <br />management control over their reference areas in th <br />point, this will allow TMI's total reference area s <br />meet the requirements of Rule 4.15,7(3)(c). <br />Saw <br />rand TMI's options, we <br />areas (one in each <br />the two in each vegetation <br />to maintain better <br />e future. More to th e <br />ize to be large enough to <br />5270E <br />