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Bowles, and Jared Ebert (no longer with the coal program), no pre -sampling meeting took place <br />with Bowie Resources representatives. <br />The Division also highly recommends that the operator inform the Division when sampling will <br />take place so if possible, a Division inspector can be on site at the same time that the sampling <br />crew is conducting sampling. This allows the Division to clarify any questions the sampling crew <br />may have, and allow the Division to observe the condition of the vegetation at the time sampling <br />is conducted. No Division inspector was present at the time of the 2016 sampling event. <br />For the 44.8 acres included in the 2016 vegetation sampling effort at the East Mine bond <br />release block, the Division concurs that the vegetation meets and exceeds the Phase II cover <br />standard. <br />Although species diversity is not a requirement for Phase II bond release, the Division evaluates <br />the Phase II vegetative data to see if the vegetative community is approaching the standard. <br />The species diversity measured on the East Mine bond release block in 2016 exhibited 4 <br />perennial herbaceous species (between 3% to 60% rel. cover) 2 were native cool -season <br />perennial grasses. 6 native shrub species were observed but not picked up in cover transects. <br />Though the 2016 sampling would not meet the Phase III diversity standard, the 2016 sampling <br />indicates that the established vegetation is approaching the diversity standards required for <br />Phase III. Therefore, the Division finds the diversity acceptable for Phase II release. <br />In accordance with Permit Section 2.05.4 (p. 63) reclaimed areas that will receive topsoil <br />replacement will average approximately 6 inches. Portions of the East Mine were disturbed <br />prior to SMCRA and the Colorado Permanent program. As such, no topsoil was salvaged from <br />these areas. Slopes were also very steep, limiting where topsoil could safely be salvaged. As <br />such, the requirement was to replace all salvaged topsoil, without a replacement depth <br />standard. <br />No verification of topsoil replacement thickness was conducted after topsoil replacement in <br />2008, 2009 or 2011 as documented by inspections reports from December 2008 to August <br />2009. <br />2 <br />