2025-03-14_PERMIT FILE - M2025016 ‎(12)‎

• Permit No: M2025016
• IBM Index Class Name: Permit File
• Doc Date: 3/14/2025
• Doc Name Note: Exhibit D - Extraction Plan
• Doc Name: Application
• From: Raptor Materials LLC
• To: DRMS
• Email Name: JR2
• Email Name: AME
• Email Name: EL1
• Media Type: D
• Archive: No

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EXHIBIT D

Raptor Materials, LLC Cogburn Sand, Gravel, and Reservoir Project February 2025
A Regular Impact (112) Construction Permit Application – Colorado Division of Reclamation Mining and Safety, Office of Mined Land Reclamation
Extraction will not occur closer than 125± feet from the face of a residential structure; unless there is a
written accommodation with the owner of the residential structure that allows extraction to occur within a
closer stated limit. Extraction will occur no closer than 25± feet from well heads and related above ground
facilities. Extraction around well heads will be concurrently backfilled to maintain a 100± foot buffer from the
balance of extracted lands. At all times, safety will take precedent and override all other conditions in time
with a matter of safety or emergency respective to any and all aspects of the approved permit.

The DRMS issued a Floodplain Protection Standard in February 2024 based largely on Mile High Flood
District guidelines. Raptor has per DRMS suggestion decided to adopt the 400-foot setback from the top of
the riverbanks to the top of the pit-side slope based on the standard. Raptor Materials intends after permit
approval to present the results of the ongoing engineering evaluation of options discussed in the standard
as a Technical Revision to obtain relief from what we are confident are very conservative setbacks.

In addition to the three above-mentioned pits, a Mineral Reserve Area is located between pit P125B and the
Saint Vrain River, identified as P125C on Map Exhibit C-2. The western portion of Pit P125B, within the 400-ft
setback from the unnamed tributary that traverses the site, is also identified as a Mineral Reserve Area.
These areas are indicated in this permit application as potential areas of future extraction, which will not
occur until and unless identified, detailed, and approved, under separate technical revision to the permit.

• 31.2 Acres – West Pit
• 10.1 Acres – Western Portion of Central Pit

Extraction will not occur within the Mineral Reserve Areas until and unless identified, detailed, and approval is
obtained under a separate technical revision to the DRMS permit. The Mineral Reserve Areas consist
primarily of floodplain setbacks from St. Vrain Creek and an unnamed stream including also an area of
potentially jurisdictional wetlands.

The remaining 94.4 acres of lands within the permitted limits may comprise planned or existing permanent
access roads, levees, previously affected areas, and areas of minor to no disturbance (including public
transportation corridors, rights-of-way, easements, permanent structures, river and stream terrace and
cottonwood corridor buffer areas), or other farm features or structures; or as otherwise determined from
included maps and aerials. These lands may also include essential support operations, including: parked
vehicles, equipment, stockpiles, etc., not otherwise explicitly indicated or shown, but reasonably associated
with operations of like kind, and may be varied in location and extent over time; or otherwise, field fit within
the permit boundary as warranted.

A complete schedule of exposed and reclaimed areas is provided in Table E-1 in Exhibit E: Reclamation Plan.

With the relatively small pits, Raptor would prefer a steady sequential advance through the initial pits
P125_S1 and P125A but for operational flexibility requires the ability to have up to three active mining areas
(area of active extraction operations) of up to 16 acres to be in production simultaneously for an anticipated
maximum active mining area of 48 acres. The flexibility to operate in up to three active mining areas allows
for management of the resource in response to market demands, coordinating operations around existing
infrastructure, water management, to ensure safe operations, or due to seasonal restrictions if required to
minimize impacts to wildlife. The maximum disturbed area will continue to grow over the life of the operation
as the post mining land use is lined water storage and as noted by the DRMS, until the basin is fully extracted
and lined, and a leak test is performed and approved by the State Engineer. Progressive regrading and lining
however will be performed and is discussed in Exhibit L.
Section (e)
(e) An approximate timetable to describe the mining operation. The timetable is for the purpose of
establishing the relationship between mining and reclamation during the different phases of a mining