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12/20/2007 3 <br />2. Please include the area disturbed by the October 8, 2006, East Panel landslide as "disturbed <br />area". Please provide a reclamation plan for the slide area and reclamation costs associated <br />with reclamation of the slide area. <br />3. Trapper Mining Inc. provided Development drill hole sealing reports on February 27, 2002 <br />(76 holes), April 4, 2005 (74 holes), and November 23, 2005 (29 holes). The reports <br />provide drill hole location, drill hole depth, and sealant volume, and stated that holes had <br />been sealed in accordance with permit section 3.3.2. These holes are included within <br />TMI's development drilling program as described in permit section 3.3.1. No reclamation <br />costs have been assigned to sealing of these holes. The majority of the holes are expected <br />to be mined through within the following year. However, there exists the potential for the <br />Trapper Mine plan to be revised and drill holes to not be mined through. Currently the <br />Division retains no bond monies assigned to sealing of development drill holes. The <br />Division maintains that a cost for sealing of the development drill holes needs to be <br />accounted for in the reclamation cost estimate. One approach would be to include a sealing <br />task for the projected annual anticipated development drill holes, provide annual sealing or <br />mined through updates with Annual Reclamation Reports along with the projected number <br />of holes anticipated for the following year. Please add costs for annual development drill <br />hole sealing into the reclamation cost estimate. <br />4. Please update T&E species and discuss potential impacts to current State and Federal <br />Threatened and Endangered plant and animal species lists (Permit Section 2.3.5). The <br />Federal and state listed species of concern may have changed over the years. To find the <br />most up to date lists, the following websites my be useful; USFWS- <br />http://www.fws.gov/mountain%2Dprairie/endspp/CountyLists/Colorado.pdf, and DOW- <br />http•//wildlife state co us/WildlifeSI)ecies/SpeciesOfConceni/ThreatenedEndangeredList/Li <br />stOffhreatenedAndEndan eg redSpecies.htm <br />The Division updated the reclamation cost estimate (RCE) with 2007 costs. This updated estimate total is <br />$18,470,032.00. This estimate includes reclamation tasks identified in the permit and does not reflect any <br />additional costs that may be associated with items identified in items No. 2 and 3 of this letter. The <br />previously required surety was $18,157,812.15. This is a difference of $312,219.85, which is accounted <br />for in the difference in unit costs and represents a 1.7% increase of the overall cost estimate. The Division <br />currently holds a bond in the amount of $18,500,000.00. At this point in time the Division does not <br />require additional bond for the required reclamation tasks, however costs associated with adequacy <br />questions Nos. 2 and 3 may change the amount of overall reclamation liability bond required. <br />The Division acknowledges that Trapper Mining Inc. is providing updates to the next five-year mine plan <br />with Permit Revision No. 6. RN5 is not providing updates to the 2008-2013 Trapper Mine plan, nor does <br />RN5 update the anticipated "worst-case scenario" for reclamation cost estimate purposes. <br />Sincerely, ' .. CZ _. <br />Jan H. Binn <br />En ironmenta Protection Specialist II <br />(303) <br />Attachment: 12-2007 RCE