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L <br /> ,12 P <br /> Memorandum <br /> Date 18 November 2019 <br /> From: R. Reilley <br /> To: Jared Ebert(DRMS) <br /> Dan MacKinnon (OSM) <br /> Re: Trapper Mine(Permit Nu. C1981010) <br /> Shrub Standard <br /> Trapper Mine in the permitting work of Permit Revision PR9 proposed changes to the shrub density standard. <br /> This proposed change was suggested in March of 2018. After discussion with DRMS,the proposed standard <br /> was been vetted by TMI with Colorado Parks and Wildlife and submitted to DRMS. All concurred the <br /> proposal was reasonable and achieved the goals set forth in TMI's permit of forage,thermal cover etc,and no <br /> objections were raised. <br /> PR9 is currently in progress as a result of changes in the mining methods of the proposed N Pit. PR9 was in <br /> process for approval in spring 2019 but was held up due to acreage discrepancies for producing a liability <br /> calculation for SLs 18 and 19. Trapper and DRMS agreed on a sequence of events and steps to achieve in <br /> advance of approving PR9 and approval of SL 18 and 19 were part of that timeline. <br /> During the time between spring 2019,approval of SLs 18 and 19 and now(November 2019),Trapper prepared <br /> a Phase III bond release (SL20) request after sampling in 2017 and 2018 and submitted this to DRMS in <br /> August of 2019. As Trapper practices contemporaneous reclamation, a bond release request is generally <br /> submitted to DRMS every other year. Thinking that PR9 be approved by the time SL20 was requested, and <br /> because there were no concerns with the shrub standard, and that Trapper was encouraged to submit the SL <br /> as there was organizational buy in on the new standard, and so that inspection could occur during clement <br /> weather,the submitted application utilized the new shrub standard in the analysis. <br /> To be clear, Trapper was encouraged to submit their bond release requests as their reclamation activities <br /> permit,and it was understood by both Trapper Mine Inc, and DRMS that no SL would be approved with any <br /> new vegetation standards until permitting action PR9 was approved or a separate technical revision was <br /> submitted regarding the proposed shrub standard. <br /> Trapper Shrub count standards comprise Section 4.4.1.3 pages 4-12 through 4-19 of Volume 4 in Trapper's <br /> permit. The purpose of the shrub standard is to provide forage, thermal cover; spring, summer and fall use <br /> and,areas for wildlife to hide,while concurrently maximizing land value for livestock grazing. <br /> Terminology: <br /> o Shrub pad a single front end loader bucket of native shrub stems transplanted into a shrub clump <br /> 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br /> Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director * . <br />