2014-01-04_REVISION - C1981010 (2)

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QpQ�Met4Si /iryc��2 United States Department of the Interior oFSURFgcF� /2� 9 O tit �O OFFICE OF SURFACE MINING m i Reclamation and Enforcement Western Region Office �9l'ONANOENFO� 1999 Broadway, Suite 3320 Denver, CO 80202 -3050 RECEIVED DEC 3 0 2013 JAN � a 2014 David Berry, Director Office of Mined Land Reclamation DMSION OF RECLAMATION Division of Reclamation, Mining and Safety MINING AND SAFETY 1313 Sherman Street, Room 215 Denver, CO 80203 -2273 RE: Approval of SL -14 Partial Phase I Bond Release, Trapper Mine, Permit No. C -1981- 010, DRMS Proposed Decision and Findings of Compliance, December 30, 2013 Dear Mr. Berry, This letter acknowledges the Office of Surface Mining (OSM) Denver Field Division's (DFD) receipt and review of the above Phase I Bond Release Proposed Decision document prepared by the Division of Reclamation, Mining and Safety (DRMS) dated December 5, 2013. DFD agrees with the findings and decision document and hereby provides OSM concurrence for the above bond release action in accordance with 30 CFR 740.15 (d) (3), and 30 CFR 906.30, Article IX, Section 24, of the State - Federal Cooperative Agreement. DRMS's Proposed Decision documents the applicant's compliance with the approved Colorado regulatory program at Rule 3.03.2. This Phase I bond release applies to 417.8 acres within parcels A -B -09, A -B -10, A -B -12, F- AB -09, F -A -10, F -A -11, F -A -12, K -A -10, K -A -11, Z -A -10, and Z -A -12. The land within this application is Private and State, and the coal in SL -14 is Federal and State owned. OSM attended the principle bond release inspection on August 15, 2013; BLM did not attend. Neither OSM nor BLM attended preliminary bond release inspections on April 24, 2012 and May 16, 2013. By letter dated December 18, 2013 the BLM provided its concurrence with SL -14 (attached). OSM interprets the BLM's concurrence to mean that Trapper Mining, Inc. (TMI) is in compliance with all BLM coal lease stipulations. Based on available documentation, OSM agrees with DRMS's determination that TMI has met or exceeded the requirements for Phase I bond release on the 417.8 acres of land as described above. In 2012 the Division estimated the reclamation liability associated with the Trapper Mine during its last permit renewal (RN6) to be $29,990,889.69. TMI did not request a reduction in bond amount with the SL -14 bond release application; should TMI reduce its liability by $2,068,397.69, the remaining liability amount of $27,922,492.00 should be sufficient to complete the remaining reclamation work at the site if the work had to be performed by the Division, including the cost of reestablishing vegetation. OSM concurs with these amounts.