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<br /> <br />'~ TRAPPER DINING INC. _.: '.:999 <br />October 3, 1988 <br />CERTIFIED P764980331 <br />Mr. Gregg Squire '" " ~ ~ ~ R `M <br />Colorado Mined Land Reclamation Division <br />215 Centennial Building ~~j ~~ ~saa -. _ <br />1313 Sherman Street c <br />~/~llVr[7 W~~u <br />Denver, co ao2o3 fiECLAMigT~pN DIV1510N <br />Dear Gregg: <br />As you may recall, during the final days of the PR-2 permit review process, you <br />stated that Trapper did not have a. diversity standard. You incorporated one via " <br />the findings document in order that PR-2 could be approved. In qur phone conver- <br />sation I agreed to what you proposed on the condition that'Trap~er be allowed to <br />evaluate and revise the, standard at a future date. Enclosed (Attachment 1) is a <br />proposed diversity standard based upon what is on page 45 of the findings docu- <br />ment .(Attachment 2) and subsequently incorporated into our permit on pages 4-128 <br />and 4-128a. The proposed changes will simplify our sampling procedure and clan- <br />fy the minimum number of herbaceous plant species which should be` re-estab- <br />lished.-.;: If the following. diversity standard changes are acceptable, we will <br />submit the changes to the Division as a technical revision. <br />Briefly stated the propose'3 changes are: <br />1. The diversity standards would be .based on the 1980 premine sampling data for <br />relative cover (Tables 1, 2, and 3) and not reference areas: <br />Rationale <br />Trapper's reclamation standards for cover, production and stem density are <br />not based on reference areas. Also, since the total number of perennial <br />- herbaceous plant species which make up .Ehe individual premine:`zange sites ~ ~~ ~'~ <br />are unlikely to chgage'significantly, anii' al'1 the other standards: are npt-,- - <br />based on` re~arence area comparisons, it does ;not. make sense to maintain"' <br />#e£erenCe areas for diversit-~. Thus, th;s proposed change would remove <br />FeferenCe areas~from~the permit:, as a basis for reelamation~success. <br />Trapper's range site reference areas were originally chosen to represent the <br />stable, mature range sites, which exisq at the mine site. Given a continua- <br />t-iron of existing climatic conditions and that the areas to be mined are:: <br />'.° under ,proper .management, one 'should riot expect the number of perennial . <br />' herbaceous plant species to vary over 'tim'e. 'Thus, historic :premine area <br />e'e com osition should be a stable ammeter Even ,the time period <br />~r•x~ r r c <br />involved, 30-40 years. <br />cont. <br />P.0. Box 18T <br />Craig, Colorado Bt626 <br />(303) 824-4401 <br />