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Mr. Forrest Luke <br />Page 3 of 3 <br />July 2020 <br />the analysis with Clover Technology's Galena software for verification purposes. Please <br />include the profile geometries and the material properties used in the stability analysis, <br />preferably in paper and electronic forms. <br />Rule 4.16.3 Alternative Land Use <br />DRMS August 2020 <br />Trapper Mine received written concurrence from the Colorado State Land Board and met the <br />criteria required for this rule and an associated proposed change in land use. <br />Rule 4.21.4(7) Performance Standard Diversions <br />DRMS August 2020 <br />DRMS notes that three diversions are proposed for construction as follows: <br />o No Name East Diversion <br />o No Name West Diversion <br />o Coyote Diversion <br />TMI submitted SEDCAD modelling for all diversions. The above stated diversions are indicated <br />on Map M51 and meet the performance standards required of this rule. <br />Rule 4.23.2 Auger Mining <br />DRMS August 2020 <br />DRMS notes that as per the above referenced rule, auger mining shall maximize coal <br />recoverability of remaining reserves after completion of mining. DRMS finds that there may be <br />areas of undisturbed coal left in unmined sections that are in excess of 2500 feet apart. Given <br />that the ownership is the State of Colorado with a Trapper Lease, please demonstrate: <br />6. Distances between centroids of coal sections meet the requirements of the above <br />mentioned rule <br />7. That undisturbed areas of coal are a minimum of 250 feet wide between each group of <br />auger openings <br />8. Or, that the coal reserves have been depleted. <br />Revised Pages <br />DRMS August 2020 <br />DRMS notes that on revised Pg 3-44 Regrade of Boxcut Spoils, in paragraph one a change from <br />800,000 to 500,000 BCYs from Dec 2019 revised pages for PR9. <br />6. Does the change in BCY's take into account both I and J pits or only JPit? <br />There may be additional adequacy questions associated with the Worst Case Bond scenario. <br />