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1, ~ ~.. • ~ • iiiiiiiiiiiiiiiiiii ~ TR9PPER MINING INC. ..~..,., February 6, 1991 ~ECEIUE~ CERTIFIED #P568141683 FEB 1 1 1991 Mr. David Berry Colorado Mined Land Reclamation Division Mined Land Reclamation Civision 215 Centennial Bldg. 1313 Sherman St. Denver, CO 80203 Dear David: Subject: Reclamation bond increase for Trapper Mine. As discussed with you previously, it has become necessary for Trapper Mine to increase its reclamation bond due to an increase in the maximum (worst case) disturbance acres asso- ciated with our current permit term (1988-1992). Various mine plan changes, all of which were approved by the Division in 1989 and 1990, have led to Trapper's inability to reclaim forecast acres as specified in our current permit term (Table 4.9-3). The mine plan changes were all necessary to insure a productive and efficient mining operation. How- ever, aresult of our greater efficiency is a decrease in proposed reclamation of approxi- mately 220 acres. Boxcut spoils, roads, coal delivery schedules, Ashmore and Browning pit mining activity, and the necessity to leave a dragline walkback road to Enfield pit have all presented obstacles to reclamation. The regrade status of most of the areas proposed for topsoiling on Table 4.9-3 is at or very near postmine contour. Trapper's current reclamation bond (permit section 1.4) is $10,509,779 and was based on regrade, topsoil, facility removal, revegetation, etc for approximately 1,250 acres of disturbance. The regrade calculations are based on four spoil rows, however in reality, seldom do three spoil rows ever exist in the field. The new bond amount is for $13,015,310 and should be more than adequate to cover any additional disturbance proposed during our current permit term. Based on my calcula- tions, our worst case regrade year is 1990 (1416 ac) and worst case topsoil replacement year 1992 (1,529 acres). The bond increment increase ($ cost) is based on a proportion of increase in disturbance acres from 1,250 to 1,543 acres. As has already been stated, the worst case regrade year according to my preliminary calculations (taking into consideration topsoil stripping, replacement and spoil regrade calculations for 1991 and 1992) is 1,416 acres (regrade makes up over 50% of the cost for bonding). P.O. Box 187 Craig, Colorado 81626 (303) 824-4401