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TBAPPB& IdINIM0INC. <br />April 7, 2010 RECE ED <br />Mr. Jason Musick APR 14 2010 <br />Colorado Division of Reclamation, Mining and Safety <br />1313 Sherman St., Room 215 tiS °`.=` dan' <br />Denver, CO 80203?jn1nq "`r'd 5`l2tY <br />Dear Jason: <br />Subject: Trapper Mine (Permit No. C-81-010) Technical Revision TR 107 <br />2009 Annual Report, Appendiz W <br />In response to comment #1, the cover sheet for the 2009 annual report lists Acres <br />Disturbed for the 2009 reporting year as 153.7 acres and a cumulative Total of 3,442.3. <br />However in section 1.2.1 disturbed acres for the year is listed at 155.4 acres. This <br />discrepancy is not in error. Trapper mine did disturb an actual acreage amount of 155.4 <br />acres for the reporting year. However, 1.7 acres of this disturbance was actually <br />redisturbance of previously reclaimed lands in Z pit. This accounts for the total used on <br />the cover sheet which is an account of all acres disturbed at Trapper mine to date. The <br />1.7 acres in Z pit had already been accounted for in previous years and was not double <br />counted. The total of 153.7 acres accounts for actual new life of mine disturbance for <br />the reporting period. <br />This explains the discrepancy in comment #2 detailing 2008 cumulative acres at 1,072.6 <br />acres and the reporting of 1,070.9 acres as last year's cumulative total. Again, the 1.7 <br />acres re-disturbed in Z pit could no longer be. a part of last year's tally, as it is no longer <br />considered backfilled/graded and or topsoiled for accounting reasons. The only way to <br />account for re-disturbed acres is to recalculate the previous year's total by subtracting the <br />disturbance to reclaimed lands. New reclamation is then added to this amount from the <br />current year. Otherwise acres previously accounted for in prior years would be double <br />counted, and the life to date totals would be considerably off. <br />These calculations seem confusing but are quite simple to explain. The reporting cover <br />sheet does not allow for reclaimed acres to be accounted for when re-disturbed. <br />Therefore, the acres must be taken out of the baseline to make the totals come out <br />properly on the cover sheet. Redisturbance occurred in parcels Z-AB-05, Z-A-07 and <br />Z-A-08 for construction of the east panel ready line. <br />P.O. Box 187 Craig, Colorado 81626 (970) 824-4401