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COLORADO Division of Reclamation, Mining and Safety Department of Natural Resources Colorado Division of Reclamation, Mining and Safety To: Robin Reilley From: Binns, Janet CC: Travis Marshall, Michael Cunningham Date: 10/14/2021 Re: Vegetation Review of Trapper Mine, C1981-010, SL23 application I have reviewed Trapper Mining, Inc.'s application for a Phase III bond release, SL23. Trapper Mining has requested Phase III bond release on a 265.5 acre Bond Release lock (BRB) of reclaimed land at the Trapper Mine in Moffat County. The 265.5 acres are comprised of 9 parcels within the Ashmore, East Flintlock, Flintlock, and Kimber pits. All the parcels included within the Bond Release Block have previously been approved for Phase I and Phase II bond release by the Division during SL14, SL16, SL18, and SL19. The approved post -mining land use is Rangeland with wildlife habitat. All parcels within the Bond release Block were seeded with the Range site A/B seed mix. The 9 parcels consist of three parcels in the Ashmore pit; A-B-09, A-B-09oak, and A-B-10, totaling 92.96 acres. Trapper's application totals these three parcels as 91.6 acres. I was unable to resolve the difference in acreage. Three parcels, subtotaling 92.8 acres, were located within the Flintlock pit. These three parcels are; F-AB-09, F-A-10, and F-A-11. Two parcels were located in the Kimber pit. These two parcels are K-A-10, and K-A-11, that subtotal 75.4 acres. One parcel, Z-A-10, consisting of 5.70 acres was located in the East Flintlock pit. All parcels within the Bond Release Block have been seeded for ten (10) or more years. The operator contracted with Osborn Industries, LLC to conduct the sampling. Vegetation sampling was conducted between July 22-30, 2020, and July 14-17, 2021. Sampling methodologies complied with Rule 4.15 and the Division's Bond Release Guidelines. Western Colorado experienced an extreme drought during the summer of 2021, but the reclaimed lands were resilient under the drought conditions. Sample transects were determined using random distribution within the entire Bond Release Block. This methodology is acceptable to the Division. Random sample distribution minimizes the potential for unintended biases, however, it is possible to miss transects falling within each parcel. The Division observes the reclaimed areas throughout the year during regular inspections, and observes each parcel during the bond release inspection, so any areas of concern will be noted. The approved reclamation success standards are: Allowable cover= 52%. Of this, a minimum of 33% cove is from perennial plant cover, and litter may contribute no more than 19%. Range Site A/B Production= 62.39 g/M2. Production includes clipped perennial grasses and perennial forbs. [No annual/biennial grasses or forbs, no shrubs, or noxious weed species] Woody Plant Density= 550 stems/acre.