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TRAPPER GIINING INC. <br />III IIIIIIIIIIIIIIII <br />999 <br />July 24, 1997 <br />DECEIVED <br />Mr. Joseph ]. Dudash <br />Environmental Protection Specialist ~~~ z 8 199) <br />Colorado Division of Minerals & Geology Division <br />1313 Sherman Street, Room 2I5 or w~merais & Ge01p9Y <br />Denver, CO 80203 <br />Re: Trapper Mining Inc-, Permit No. C-81-010 <br />Bond Release Plan Changes, Technical Revision.TR-71 <br />Dear Mr. Dudash: <br />This letter responds to the TR-71 comments outlined in your letter dated May 9, 1997. Enclosed <br />please find several permit pages (4-116, 4-119, 4-123) that aze revised with this response <br />document separately from the original submittal. <br />Trapper offers the following responses to DMG's comments: <br />General Comments I .. 2., and 3. <br />As discussed between the undersigned, David Berry and Tom Kaldenbach during a meeting in <br />Denver on July 10, 1997, Trapper had no intention of opening up the previously approved <br />vegetation cover and production technical standards for review with this proposed revision. The <br />pages in Section 4.4 that include the technical standards were included only because the entire <br />section was repaginated. As agreed, Trapper will retain these technical standards. We also <br />agreed that as Trapper approaches future Phase III bond release applications, any specific <br />wncems within the framework of the technical standards will be discussed and any appropriate <br />changes will be considered. <br />Specific Question No. 1. <br />Since the time that the original TR-71 application was submitted in June 1996, Trapper has <br />conducted direct count woody stem sampling on six shrub clumps, which represent across- <br />section of all shrub clumps constructed to date, during July and August 1997. That sampling <br />experience taught us several things. First, the average stem wont for those six clumps was <br />16,777 (data enclosed), well above the current 3,764-stems/clump density standard. Sewnd, <br />sampling the shrub clumps was extremely difficult because of the dense, tangled nature in which <br />stem bases are situated. Third, mature shrub pads within clumps are generally shallow, shady <br />depressions that are highly preferred by poisonous rattlesnakes. <br />Based on our 1996 sampling experience, it became obvious that direct woody stem density <br />counts were unnecessary, impractical and dangerous. Trapper is therefore proposing ro drop the <br />shrub clump density standard in favor of direct approval of wmpleted shrub clumps, on an <br />P.O. Box 187 Craig, Colorado 81626 (303) 824-4401 <br />