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Page 12 <br />2018 requested 564 acres of disturbance. Table 3.1-3 indicates 3121.8 <br />acres as projected disturbed acres for the end of the permit term in 2022 <br />taking into account Phase III bond released acres at the end of 2017. This <br />value appears to represent open acres, and reclaimed acres. TMI's table <br />1.4-1 in Appendix A utilizes 1584.6 acres for the PR9 worst case bond. <br />Utilizing TMI's information this value appears to represent a summation of <br />the open acres at the beginning of the permit term, topsoil removal and <br />final regrade. Understanding that table 3.1-3 represents projected acres <br />DRMS is unclear about this basis. DRMS records indicate the disturbed <br />acreage at 3,326.3 and must hold bond for all affected land. Also, TMI's <br />numbers in the PR9 bond calculations do not corroborate the acres <br />submitted in TMI's Annual Reclamation Report and this document may be a <br />more accurate representation of acreages for utilization in bonding <br />calculations. Also, since PR9 has been submitted, a number of TRs and MRs <br />have been submitted changing the affected area and some of those <br />approvals may overlap what was originally proposed with PR9. <br />DRMS Comment 2. Given the approved MR's and TR's since the PR9 application, <br />DRMS would like documentation from TMI demonstrating that the net increase in <br />affected land does not exceed the originally proposed 564 acres. <br />Trapper Response to 2. During the initial submittal of PR -9 a greater acreage was <br />expected to be utilized during the pen -nit term. Following that submittal several revisions <br />to our mine plan and pit orientation have reduced the number of required acres to be <br />disturbed during this permit term. See response to Comment 3 below. <br />DRMS Comment 3. As the worst case bonding scenario should represent the affected land <br />DRMS is approving in the PR9 permitting action, please provide DRMS with acreage <br />representing the net increase in affected area. <br />Trapper Response to 3. After careful review of TR -119, 121 and 124 and the acreages <br />associated with them, a net increase of only 1.4 acres will be required to be added to the <br />affected land acreage for PR -9. As stated above, the needed disturbance acreage for PR - <br />9 has decreased from 564 acres to 454.7 acres. TR -119 requested an increase of 245.4 <br />acres and TR -124 requested an increase of 201.4 acres. Another permitting action, TR - <br />121 was also completed approving the construction of the Johnson Coal Stockpile at a <br />projected 6.5 acres of additional disturbance. These three actions equal 453.3 acres. The <br />two requests of mining related disturbance are the same areas included in the PR -9 <br />application. The Johnson Coal Stockpile has also been taken into consideration on Table <br />3.1.3 and is accounted for in the 454.7 requested acres in PR -9. Therefore, only 1.4 acres <br />remain to be approved for disturbance with the approval of PR -9. <br />DRMS understands that TMI's permit provides for a maximum of 200 <br />development drill holes. However, TMI's bonding proposal bonds for 20 <br />development drill holes. <br />