2025-08-06_REVISION - C1981019 (16)

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PHASE I To determine compliance with Colowyo's approved approximate original contour (AOC) in Areas 1-4,the Division used visual and on the ground observations to ensure that the release areas met all applicable criteria for Phase I bond release, as noted above. The Division's inspection report, dated May 21, 2025, describes in detail the state of each area and also provides photographs for these areas. Please reference the inspection report for this information. Overall,the backfill and grading work done in Areas 1 —4 is consistent with the approved reclamation plan and meets the Phase I Bond Release criteria.No erosional issues were identified in any of the areas,no slumps were observed, areas were graded in such a manner that encouraged approved drainage paths, and overall,these areas blended into the surrounding slopes and vegetation seamlessly. Through additional permit review, it was discovered that the Division had already released the area listed as Area 1 as part of a Phase I Bond Release Application (SL-13) in 2018. The SL-13 Findings refer to this area as `C05' and approved a Phase I release of the area. Therefore,the Division cannot approve a duplicate Phase I release of the Area 1 acreage (0.1) acres under SL-24. The acreage can, however,be Phase II and III released as part of release requests in the future. Additionally, it appears that a reclamation line item for Area 1 / `C05' no longer exists within the most recent bond calculation Midterm No. 9 (MT-9). Area 2 and Area 4 acreages are associated with a raw water pipeline.Area 2 is located in Collom Pit and Area 4 is located north of East/West/ South Taylor Pit. The Division's most recent reclamation cost estimate (MT-9) includes two reclamation line items which reference a raw water line: Task#444 (Regrade Topsoil for Raw Water Line) and#445 (Reseed Collom Raw Water Line). However,upon review of previous permitting and bonding history,the Division has determined that Tasks#444 and #445 are associated with the raw water pipeline under the Collom Haul Road specifically and not associated with reclamation of pipeline in release Areas 2 and 4. The Division has determined that Area 4 is currently not bonded for under the most recent MT-9 bond calculation. Despite a lack of reclamation costs currently associated with Area 4,the Division can still proceed with releasing Phase I acreage associated with Area 4 under SL-24,but no monies will be returned for this area. The most appropriate reclamation line item tasks to be associated with Area 2 are Tasks#415, #416, and#453. This has been reflected below in Table 3. To determine compliance with Colowyo's approved approximate original contour (AOC) in Area 5 of the SL-24 r e 1 e a s e areas, elevation data provided in the SL-24 partial bond release application on M a p 2 was compared to GPS data collected by the Division. A total of twelve GPS points were taken, four along Transect A-A' and eight along Transect B-B' at approximately 400 feet intervals. The Division navigated to the points using the ArcOnline Field Maps application. A GPS data point was collected at each point,utilizing an iPhone 13 as the surveying unit. Locations of these points are shown on Figure 2 of this document. Each reclamation parcel was also visually inspected to ensure the area was graded and blended in with the adjacent reclaimed areas. During the inspection,no signs of erosion or issues were encountered. The elevation data collected for the West Pit by the Division was compared to elevation information provided in the SL-24 Bond Release application and shown on Table 4 of this document. After comparison,all elevation points taken with the iPhone 13 by the Division across transects A-A' and B-B' were found to have an average difference of approximately 12.5 feet from Proposed Decision and Findings of Compliance Partial Phase I Bond Release SL-24 Page 7 of 14