2017-07-11_REVISION - C1981010

• Permit No: C1981010
• IBM Index Class Name: Revision
• Doc Date: 7/11/2017
• Doc Name: Adequacy Review - Preliminary
• From: DRMS
• To: Trapper Mining, Inc
• Type & Sequence: PR8
• Email Name: RAR
• Email Name: DIH
• Media Type: D
• Archive: No

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Trapper Mine PR8 Preliminary Adequacy Review
Prepared by: R. Reilley July 2017
Trapper Mine Inc., PR8 Preliminary Adequacy Review of
Stipulation 22 and Coal Rules

Stipulation 22
Prior to disturbance within the 795.72-acre PR7 permit expansion area, the permittee must submit and
receive approval of an application for a permit revision that contain the following required information
for this area:

a) A narrative of land capability and productivity before any mining in accordance with Rule
2.04.3(2)(b).

May 2017 Trapper
The land within the PR-7 expansion area and surrounding areas is undeveloped and unmanaged land and is
used primarily for rangeland and wildlife habitat. The land is privately owned and there are no public lands
or parks within or adjacent to the PR-7 Mine Expansion Area. There are no lands within or adjacent to the
PR-7 Mine Expansion Area associated with the National Parks System, the National Wildlife Refuge
System, the National System of Trails, the National Wilderness Preservation System, the Wild and Scenic
Rivers System, National Recreation Areas and National Forests.

Information from soils and vegetation reports for the PR-7 area, combined with information determined
during a field evaluation conducted by Ranch Advisory Partners for TMI's Williams Fork Land Company
in July 2014 to assess rangeland health and wildlife habitat, were used to determine land capability and
cattle carrying capacity of the PR-7 expansion area.

The land capability for most of the PR-7 lands is high for wildlife foraging. Table 2.5-5 to be inserted into
the permit document shows the vegetative productivity by soil type for the soils within the PR-7 area in
accordance with the Natural Resources Conservation Service Web Soil Survey at:
http://websoilsurvey.nrcs.usda.gov/app/HomePage.htm. Based on the field evaluation by Ranch Advisory
Partners, much of the PR-7land is too steep for effective cattle grazing with only 86 of the total 795.71
acres assessed as good cattle grazing area. Except for a spring at the extreme south end, there are no water
sources available within the of the PR-7 expansion area; however, there is water on mining and reclaimed
lands to the west and across County Road 33 to the east. The cattle carrying capacity for the 86 acres of
grazeable land is approximately 11 animal days/acre and approximately 2.7 acres/animal unit month.

The discussion of the land capability and productivity is contained in Section 2.5 of the permit document.
A narrative discussion of the capability and productivity for the PR-7 area has been added to Section 2.5
of the permit document with the replacement pages 2-181 and 2-181a attached to this letter for review.

July 2017 DRMS
This section of the stipulation is adequately addressed.

May 2017 Trapper
b) Cultural and historic resource information for areas proposed or likely to be affected by surface
mining activities in accordance with Rule 2.04.4.

In 2013 and 2014 three Class III surveys were conducted by Grand River Institute within the 795.71 acre
expanded permit area as part of PR-7. The surveys also included approximately 2,568 acres to the east of
the revised permit boundary. The area covered by these surveys is shown on the enclosed revised Map M45
and the results of these surveys are enclosed to be inserted in Appendix K. The surveys identified 12 sites for