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2 <br />acreage. The 2015 and 2016 ARRs reported 82.7 acres of Phase I bond release, yet the 2017 <br />ARR reported 63.68 acres of Phase I bond release. Please update BRL's records to reflect the <br />correct bond released acreage. <br />The Division reviewed BRL's very detailed Reclamation Summary table found on page 30 of the <br />2018 ARR. The Division tallied up the seeded and topsoiled acreage in this table with the <br />following results: <br />100.93 acres have been seeded with perennial seedmix. 2.62 acres have been seeded with <br />temporary seedmix #6, 48.49 acres have been topsoiled since 2002. 21.21 acres have <br />been seeded without being topsoiled since 2002. <br />These values are out of agreement with BRL's acreage values reported in the 2018 ARR. Does <br />BRL have a record showing where the reported ARR values were derived? <br />The Seeding Summary table included on page 31 also does not add up. BRL reports that the <br />cumulative total for seeded acres is 105.97. However, acres seeded for 10 years or less equals <br />21.56, and acres seeded for greater than 10 years equals 54.29. 21.56 plus 54.29 only equals <br />75.85 acres. Please provide an explanation as to why these values do not agree. <br />The Division appreciates the historical information that BRL includes in the report, but we need <br />to understand why some of the reported values appear to be in conflict. <br />Items that need to be resolved with the 2018 Annual Reclamation Report are: <br />1. Please report the unreclaimed acreage in the "Long-term Facilities" column. <br />2. BRL's reported bond release acreage needs to agree with the Division's values. <br />3. Please provide an explanation as to why the reclamation summary values for seeding and <br />topsoiling are not in agreement with those values reported on the Annual Reclamation <br />form. <br />The Division recognizes that some of this history may have been explained to previous <br />specialists, but as the mine is moving towards potential bond releases, we want to assure these <br />discrepancies are resolved prior to BRL requesting additional bond release. I am including my <br />Excel worksheet to illustrate where I derived my values. <br />Please call me if we need to discuss this further. <br />O� C01p <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 <br />'� 1876 <br />