Conversation Contents

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1 Conversation Contents May not be the first but is definitely a documented meeting Attachments: /346. May not be the first but is definitely a documented meeting/1.1 Summary of July 2 Meeting to Storzer and Halter.pdf "Bodus, Theresa" <tbodus@blm.gov> From: Sent: To: Subject: Attachments: "Sodus, Theresa" > Tue Oct :21 :30 GMT-0600 (MDT) "Gettinger, Dean S" May not be the first but is definitely a documented meeting Summary of July 2 Meeting to Storzer and Halter. pdf Hello, This may not be the first document which outlined their request for a lease renewal but it clearly was discussing it by the notes. It is not clear that I would have a copy of the original correspondence regarding the request for a renewal but this document outlined the discussion on how to move forward on the NEPA needed for the renewal. Theresa Theresa M. Bodus AFM Minerals Bureau of Land Management Northeastern States Field Office 626 E. Wisconsin Ave, Suite 200 Milwaukee, WI Work BLM

2 SUMMARY OF MEETING Representatives of Twin Metals Minnesota LLC ("Twin Metals Minnesota") met with the Bureau of Land Management ("BLM") and the United States Forest Service ("USPS") on July 2, To accommodate representatives from both agencies, the meeting was held simultaneously via videoconferencing at USPS's offices in both Milwaukee, WI and Duluth, MN. I. ATTENDEES A. Milwaukee, WI Offices Twin Metals Minnesota Representatives 1. I. Daniel Colton, General Counsel and Vice-President of Regulatory Affairs 2. Andy Spielman, Hogan Lovells US LLP 3. Peter Schaumberg, Beveridge & Diamond, P.C. 4. Aleava Sayre, Leonard, Str~et and Deinard BLM Representatives 1. Dr. John Lyon, State Director for BLM- Eastern States 2. Mark Storzer, Milwaukee Field Manager 3. Theresa Bodus, Assistant Field Manager Mineral Resources 4. Steve Mahoney, Office of the Solicitor, Department of the Interior 5. Randy Anderson, Team Lead for Wild Horse and Burro (NEPA coordinator) USPS Representatives 1. Anthony Erba, Director of Planning, Appeals, and Litigation 2. Troy Thompson, Regional Hydrogeologist 3. John Vandlik, Attorney, Office of General Counsel 4. Vince Vukelich, Attorney, Office of General Counsel B. Duluth, MN Offices Twin Metals Minnesota Representatives 1. Anne Williamson, Vice-President of Environment and Sustainability 2. Dennis Shubbe, Director of Environment and Sustainability 3. Greg Fontaine, Leonard, Street and Deinard USPS Representatives 1. Brenda Halter, Forest Supervisor 2. Timothy Dabney, Deputy Forest Supervisor 3. Mary Shedd, Natural Resources Staff Officer 4. Eric Wirz, Geologist BLM002669

3 II. PURPOSES OF MEETING The purpose the of the meeting was to: Provide BLM and USFS with an update on recent Twin Metals Minnesota project activities and provide an overview of the corporate structure of Twin Metals Minnesota; Reach general understanding on the path forward regarding 1) whether administrative renewal ofthe Maturi West and Spruce Road Leases either is not subject to NEPA or subject to a Categorical Exclusion ("CX"); 2) a Simple Lease approach for Maturi East Prospecting Permits and 50846; and 3) authorization for installation of monitor wells on federal lands for which TMM does not have a lease, permit, or permit application. III. MAJOR TAKE-AWAYS FROM MEETING Lease Renewal Twin Metals Minnesota provided general background on the two existing federal mineral leases MNES 1352 and Twin Metals Minnesota suggested that a CX is appropriate for the administrative renewal ofleases MNES 1352 and 1353 for several reasons, including: (1) previous lease renewals were subject to a CX or excluded from NEPA; (2) the lease renewal is an administrative decision that flows from the original lease, which provides for three renewals; (3) BLM has two appropriate CXs, which it has applied to preference right leases under the same regulations; and ( 4) this decision can have no significant environmental impacts. BLM indicated that this approach may make sense, but will need to review the applicable materials and discuss this issue further. USFS asked whether NEP A is triggered at all (i.e., is a CX necessary), but it will need to review the issues further. Preference Right Lease Application Twin Metals Minnesota described the current approach for determining the expiration date of prospecting permits MNES and and highlighted why it needed to secure mineral tenure in the near-term. Twin Metals Minnesota explained the "Simple Lease" approach, which would include issuance of a preference right lease that did not authorize mining, that would include appropriate stipulations, and that would be subject to an EA with any future approval of a Mine Plan of Operations subject to an EIS. BLM and USFS both emphasized the importance ofthe stipulations included in the lease, and Twin Metals Minnesota agreed to work with both agencies on drafting stipulations that would be mutually acceptable. 1 BLM002670

4 BLM indicated that it could see a path forward, but needed to discuss further. USPS agreed more discussion would be required.. Hydrogeological Study- Installation of Monitor Wells Twin Metals Minnesota presented an overview of the hydrogeological study and focused the discussion on the form of BLM authorization required for installation of monitor wells on lands for which TMM has no lease, permit, or permit application. Twin Metals Minnesota explained why prospecting permits held by other companies did not preclude installation of monitor wells on those lands. Twin Metals Minnesota then identified several potential forms of BLM authorization, including a license agreement, a right of way, and a use permit. BLM indicated that it would need to further evaluate which form of authorization was appropriate, and USPS indicated its decision would incorporate the form of BLM authorization that was required. There was additional discussion of the forms of USPS authorization that may be applicable to both TMM lease/permit/permit application lands and those lands on which TMM has no lease, permit or permit application in place. USPS indicated that it needs to further consider whether any additional NEP A is required for the monitor wells (and if so, the scope thereof), which may be dependent on the form of authorization requests (plan of operation amendment vs. special use permit) submitted by Twin Metals Minnesota IV. ACTION ITEMS A. Twin Metals Minnesota to provide copies of presentation. B. BLM and USPS to schedule a follow-up meeting with Twin Metals Minnesota for late July. Dr. Lyon indicated that BLM would try to be in touch with Twin Metals Minnesota as to possible dates by the week of July 9, C. Twin Metals Minnesota to provide a simple 18-month timeline of Twin Metals Minnesota Activities. D. Twin Metals Minnesota to provide a break-down of its federal, state, and private mineral resource estimate. E. Twin Metals Minnesota to provide relevant NEP A documents relating to previous/other lease renewals. P. Twin Metals Minnesota to provide corporate documents. G. Twin Metals Minnesota to prepare this summary of meeting. H. BLM and USPS to coordinate on decisions regarding: 2 BLM002671

5 Lease Renewal 10 Form of decision, if any, that USFS needs to make with respect to the renewal of the two leases 20 NEPA review, if any, for the administrative renewal of the existing federal leases MNES 1352 and 1353, which have previously been renewed twice without an EA or EIS, including whether BLM will utilize one of the two BLM CXs used for other recent solid mineral lease renewals Preference Right Lease Application 3 0 USFS' s decision space for approving a preference right lease for prospecting permits MNES and Form of stipulations appropriate for a "Simple Lease" that will be subject to anea Hydrogeological Study -Insta(lation of Monitor Wells 50 Form ofblm and USFS authorizations required for installation of monitor wells on lands for which Twin Metals Minnesota does not have a lease, permit, or permit application 60 Whether the installation of monitor wells, either on the Twin Metals Minnesota minerals lease and permit lands or minerals permit lands of third parties, constitute "prospecting" for purposes of minerals permits and the implication of this determination on agency approvals and NEP A 7 0 Communications with other holders of prospecting permits 80 Scope ofnep A review required, if any, given recent issuance of the prospecting permit FEIS and the previous Kawishiwi EA 3 BLM002672