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Submittal of Bond Release Application and Completeness Determination by the Division <br />The Division received TMI's bond release application SL -15 on September 30'h, 2013. The application <br />was found complete on October 31st, 2013, after the Division received proof of publication of the <br />applicant's public notice. The completeness determination was made in accordance with Section <br />3.03.2(1)(d). <br />TMI submitted the bond release application following the procedures described in the Act and <br />Regulations. Furthermore, the application is in agreement with the Division's Guideline Regarding <br />Selected Coal Mine Bond Release Issues, dated April 18, 1995. <br />Public Notice <br />TMI published notice of the bond release application in the Craig Daily Press once weekly for four <br />consecutive weeks, beginning on September 16, 2013. TMI also notified landowners within and <br />adjacent to the mine permit area, and other interested parties of the application for bond release, as <br />required by section 3.03.2(1). The Division received no written comments, objections, or requests for <br />an informal conference regarding the bond release application. <br />Bond Release Inspection <br />The Division scheduled and conducted a bond release inspection on November 20, 2013. Notification <br />of the inspection was sent to the operator, surface owners, Bureau of Land Management (BLM) and <br />the Office of Surface Mining (OSM). The site inspection was conducted in accordance with Section <br />3.03.2(2). Jared Ebert represented the Colorado Division of Reclamation, Mining, and Safety <br />(Division). The Operator was represented by Graham Roberts of Trapper Mining, Inc. Also at the <br />inspection were Christine Belka and Spencer Shumate of the Office of Surface Mining, and Jerod <br />Smith with the Colorado State Land Board. Please see the November 20, 2013 inspection report for <br />details of the Division's observations and the Observations and Findings Section of this document. <br />Adequacy Review of SL -15 Application <br />The SL -15 bond release application was adequate as submitted. <br />III. CRITERIA FOR BOND RELEASE <br />Under Colorado's Permanent Program, the process of releasing the reclamation bond for a mine site is <br />explained in Rule 3.03 and further described in the Division's 1995 Guideline Regarding Selected Coal <br />Mining Bond Release Issues. For Phase I bond release, Rule 3.03.1(2)(a) states, "Up to sixty percent of <br />the applicable bond amount shall be released when the permittee successfully completes backfilling, <br />regrading, and drainage control in accordance with the approved reclamation plan." <br />Evaluation and inspection of the reclaimed areas was based on the specific requirements of the reclamation <br />plan and the functional requirements of the post- mining land use. Criteria for bond release included the <br />following based on the 1995 guidelines noted above: <br />1. Hillslope and drainage channel gradients and general design compliance; <br />2. Performance of the reconstructed topography. Symptoms of failure or instabilities such as slumping <br />or exposed highwalls were examined; <br />Trapper Mine Page 5 January 2014 <br />SL -15 Phase I Bond Release <br />