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The Division's "Guideline Regarding Selected Coal Mine Bond Release Issues" dated April 18, 1995 <br />outlines what the Division uses to evaluate if reclaimed lands qualify for Phase II bond release. In <br />summary, the Division evaluates the following: <br />1.) Topsoil replacement thickness. <br />2.) Vegetation cover and "bare areas ". <br />3.) Species composition. <br />4.) Re- establishment of essential hydrologic functions on Alluvial Valley Floors (AVF's). <br />5.) Erosional features. <br />6.) The condition of the sediment ponds and any needed maintenance on the pond receiving runoff <br />from the bond release parcels. <br />III. OBSERVATIONS AND FINDINGS <br />PHASE II <br />During the bond release inspection conducted on October 15, 2014, the following observations were <br />made. For all parcels, the vegetative cover was consistent with the vegetation sampling results reported <br />in the SL -16 application. Species composition was generally consistent with the species reported in the <br />SL -16 application, with relatively large quantities of Wheatgrasses (Agropyron spp.), Sheep Fescue <br />(Festuca ovina), Kentucky Bluegrass (Poa pratensis) and Great Basin Wildrye (Elymus cinereus). The <br />dominant perennial forbs were Western Yarrow (Achillea millefolium) and Lewis Flax (Linum lewisii). <br />Rubber Rabbitbrush (Chrysothamnus nauseosus) and Big Sagebursh (Artemisia tridentate) were the <br />dominant shrubs present. Noxious weeds such as Cheatgrass (Bromus tectorum), Musk Thistle <br />(Carduus nutans) and Canada thistle (Cirsium arvense) were observed during the inspection. The thistle <br />patches were small in number and did not appear to be significantly impacting the establishment of the <br />desired vegetation. Cheatgrass was observed throughout the site and is a common species found <br />throughout Moffat County. Overall, it did not appear cheatgrass was significantly impacting the <br />establishment of the desired vegetation. Small bare areas devoid of vegetation were observed, but these <br />areas were small and constituted an insignificant amount of the bond release area. Alluvial Valley <br />Floors are not located within the bond release block. In general, erosion is not a problem in the SL -16 <br />bond release parcels. <br />Permitted topsoil depth replacement on rangeland is 12 inches plus or minus 2 inches (permit page 4- <br />256). TMI verifies topsoil replacement thickness by scraper load counts. A load count for each <br />reclamation parcel is included in the bond release application. Topsoil replacement depth verification <br />was conducted during monthly inspections as documented in DRMS inspection reports dated October <br />11, 2005, October 24, 2007, October 22, 2008, November 11, 2009, April 20, 2010, August 15, 2013 <br />and October 15, 2014 for the SL -16 bond release parcels. All parcel areas verified by the Division were <br />within the permitted topsoil replacement thickness. <br />Bond Release Blocks Delineation <br />The reclaimed parcels are compared to three different range standards based on elevation: range site C, <br />range site B, and range site A. Range site C standards apply to elevations below 6700 feet, range site B <br />Page 7 of 10 <br />