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release request. The vegetation within this parcel was comprised primarily of weedy species. No transect <br />data points fell within the westerly 1.8 acre parcel A -C-04. The Division requested additional narrative <br />for the proposed release of Deer Pond and additional information on an unidentified well present in parcel <br />D -C-04 observed during the inspection. TMI submitted a response to the Division's adequacy review on <br />September 13, 2016. This response addressed all the adequacy items including the removal of the 1.8 <br />acres in parcel A -C-04 from consideration for Phase III bond release. The remaining 3.4 acres of A -C-04 <br />was designated as A -C -04A and the excluded 1.8 acreages as A -C-0413. The original SL -17 proposal was <br />for 450.2 acres and with the September 13, 2016, response from TMI the acreage was reduced to 448.4 <br />acres. The unidentified well was addressed with the submission of minor revision MR -223 to include this <br />well as part of Trappers future ash well monitoring network. The Division has reviewed MR 223 and will <br />approve the minor revision along with the issuance of SL -17. <br />III. APPROVAL CRITERIA FOR BOND RELEASE <br />Phase I Bond Release <br />Rule 3.03.1(2)(a) states, "Up to sixty percent of the applicable bond amount shall be released when the <br />permittee successfully completes backfilling, regrading, and drainage control in accordance with the <br />approved reclamation plan." All lands requested in the current Phase III bond release application, SL -17, <br />received Phase I bond release during SL -5 approval (June 11, 2004) and SL -8 approval (November 21, 2008). <br />Phase II Bond Release <br />Rule 3.03.1(2)(b) states, "Up to eighty-five percent of the applicable bond amount shall be released upon <br />the establishment of vegetation which supports the approved post -mining land use and which meets the <br />approved success standard for cover based on statistically valid data collected during a single year of the <br />liability period". In regard to Phase II bond release, Rule 3.03.1(3)(b) also states, "No more than (60) <br />percent of the bond shall be released so long as the lands to which the release would be applicable are <br />contributing suspended solids to streamflow or runoff outside the permit area in excess of pre -mining <br />levels as determined by baseline data or in excess of levels determined on adjacent non -mined areas". <br />The post -mining land use for the land applicable to SL -17 is rangeland. There are three different range <br />communities to which the reclaimed parcels are compared. Range site C standards apply to elevations <br />below 6700 feet, range site B standards apply to elevations above 6700 feet and below 7200 feet, and <br />range site A standards apply to elevations greater than 7200 feet (permit section 3.6.3.5). Contiguous <br />areas of range site A and range site B that were seeded in the same year and that received similar <br />reclamation practices may be lumped together into one range site AB parcel. Small isolated parcels of <br />Trapper Mine Page 5 November, 2016 <br />Phase III Bond Release (SL -17) <br />