2022-10-26_REVISION - C1981010 (7)

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Ms. Robin Reilly, CDMG Re: RN-08 Permit Renewal Page 12 Trapper Response: Revised pages 1-5 to 1-7a have been provided that should demonstrate all applicable changes to Trapper ownership and control. Further required revisions will be addressed as requested. Rule 2.05.2 Operation Plan Permit section 3.0 presents a thorough discussion of the operations and reclamation plans, describing mining methods, equipment and anticipated production tonnage. This aspect of the Rules is adequately addressed with the exception of: August 2022 DRMS 4. Please update table 3.1-1 Maximum Annual Production if any changes are anticipated for this permit term. 5. Please update table 3.1-3 Approximate Yearly Disturbance and Reclamation by Phases (permit pg. 3-13) to reflect projected acreages for the new permit term. 6. Please also discuss the Birth of reclamation work accomplished in 2020 and 2021 as compared with the proposed mining plan. Permitting Action date BG Proposed BG Completed TR125 2019 ARR 197 196 TR127 2020 ARR 74 19 TR129 2021 ARR 384 0 Trapper Response: 4. Table 3.1-1,page 3-10, has be revised and included with this response. Production values are for the upcoming permit term. 5. Table 3.1-3,page 3-13, has be revised with projected disturbance and reclamation acreages for the upcoming permit term. 6. During the past three years Trapper has faced several challenges and shortcomings in achieving the proposed reclamation. Changes in mining methods have been less productive than originally forecast. Due to unexpected attrition rates, a reduction in workforce, and a lack of available workers in the area to make up the gap, the operation has had to divert internal resources to coal production over reclamation operations. Trapper did employ multiple contractors over the summer of 2022 to catch up proposed regrade in the DIE-Pit area, and has prepared the L-Pit for extensive regrade in 2023. In the currently proposed PR-11 application, reclamation liability has been re-accounted for in the DIE-Pit, and future proposed reclamation will encompass the majority of the site by 2027. Rule 3.02.2 Performance Bond DRMS understands that no additional disturbance is anticipated with the renewal. A reclamation cost estimate is being finalized and will be forwarded o Trapper Mine Inc as soon as possible. DRMS has the following questions concerning costs for reclamation: As reclamation has not been completed in D Pit and backfilling and grading is currently being undertaken there DRMS will include costs for back filling and grading as well as topsoil and seeding D Pit to the RN8 cost estimate.