2021-03-25_REVISION - C1982057

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 3/25/2021
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: Seneca Property LLC
• Type & Sequence: SL6
• Email Name: RAR
• Email Name: JLE
• Media Type: D
• Archive: No

News Media, Steamboat Pilot once weekly for four consecutive weeks,beginning 27 October 2019. Seneca
Property LLC also notified land owners within and adjacent to the mine permit area,and other interested
parties of the application for bond release,as required by Rule 3.03.2(1).
No comments,written objections,or requests for an informal conference regarding the bond release
application were received by the Division.
The Division scheduled and conducted a bond release inspection on 21 July 2020. The site inspection was
conducted in accordance with Rule 3.03.2(2). The Division notified the operator, surface owners,Bureau of
Land Management(BLM),the Office of Surface Mining(OSM),and the Colorado State Land Board of the
inspection via certified mail. Attendees included:
o Miranda Kawcack, Seneca Properties LLC (SPL)
o Christine Belka, Office of Surface Mining Reclamation and Enforcement(OSMRE)
o Ana Lash,Hayden Library Director
o Christine Epp,Hayden Library Board
o Robin Reilley, GISP; Colorado Division of Reclamation,Mining,and Safety(DRMS)
DRMS conducted the bond release inspection with available sister agencies in attendance on 21 July 2020
and provided the associated inspection report to SPL,BLM,and OSMRE via electronic transmission on 30
July 2020. DRMS received the OSMRE inspection report from Christine Belka on 3 August 2020.
Reclamation for the requested Phase II,and phase II/III SL6 bond release areas was conducted between 1990
and 2007. The reclamation parcels selected for the SL6 bond release were seeded between 2003 and
2007. The requested lands comprise bond release block 3 (BRB3),totaling 804.1 acres, and an additional
12.5 acres of permanent roads,bringing the total to 816.6 acres. The phase II/III areas represents the
southern portion of the BRB while the phase III represents the northern portion. Map 1 submitted with
the application illustrate the parcels associated with each requested phase. Reclamation activities are
documented in the Annual Reclamation Reports submitted to DRMS. All areas in this application
received formal phase I bond release through permitting action SL3. A portion of the phase II/III request
received formal phase II release through permitting action SL5. The remainder is requested for phase II
in the SL6 permitting action. A map of the bond release parcels was provided in the application.
Adequacy Review
Adequacy questions were provided to SPL on 20 August 2020 requesting a sediment demonstration,water
quality information and additional data on TSS for ponds and outfalls. Updates to application pages were
also requested to assure that the correct year of data had been submitted. The sediment demonstration and
additional water quality information was received by DRMS on 12 January 2021.
II. CRITERIA AND SCHEDULE FOR BOND RELEASE
The Division evaluated Seneca Coal Company's request for Phase II and II/III bond release on 816.6 acres in
the SL6 application. Under Colorado's Permanent Program,the process of releasing the reclamation bond for
a mine site is explained in Rule 3.03 and further described in the Division's 1995 Guideline Regarding
Selected Coal Mining Bond Release Issues. The bond release process involves three phases. At Phase II,
Rule 3.03.1(2)(b) states:
"Up to eighty-five percent of the applicable bond amount shall be released upon the establishment of
Permit Number C1982057 Prepared by: R.Reilley NIS,GISP
SL6 Phase II and III Page 4 of 16