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H. OBSERVATIONS AND FINDINGS <br /> In conjunction with Midterm Review No. 9(MT9)and Minor Revision No.264 (NM64) and in accordance <br /> with Rule 3.02.2(4),the Division has reviewed the adequacy of the reclamation bonding instruments and the <br /> adequacy of the reclamation cost estimate. There are currently four corporate sureties in place for the Colowyo <br /> Coal Mine,which total in the amount of$119,000,000.00. <br /> A reclamation cost estimate was sent to CCC with the MT9 review document on May 5, 2025. On June 9, <br /> 2025, CCC submitted NM64 to address adequacy items raised in the MT9 review. During the review of <br /> NM64,the Division and CCC reviewed the reclamation liability at the site and an updated reclamation cost <br /> estimate was produced by the Division based on the MT9 estimate and questions raised by CCC. The Division <br /> provided a copy of the reclamation cost estimate to CCC on June 25,2025. The updated total required liability <br /> calculated with NM64 was $131,989,553.00. CCC subsequently reviewed and accepted the Division's <br /> estimate in a letter dated June 27,2025. <br /> Through review and approval of Surety Release No. 24 (SL24), it was discovered that the reclamation cost <br /> estimate amount calculated under NM64 required additional updates to incorporate new reclamation tasks. <br /> Please see the Division's Findings of Compliance Document for SL24,dated August 6,2025 for further details. <br /> Through the SI2 adequacy review period,the Division consolidated changes to the reclamation cost estimate <br /> for the Colowyo Coal Mine made under NM64 and SL24. Additionally, task duplication errors that were <br /> observed in the NM64 site wide reclamation cost estimate were removed. <br /> SI2 reduces the required bond amount calculated with MR264.However overall, SI2 will still initiate the need <br /> for an increase in required surety from CCC's currently available financial warranty amount. The Division <br /> provided CCC with a final required bond amount. CCC accepted this final amount in a letter to the Division <br /> dated September 15, 2025. The current required surety set for the Colowyo Coal Mine is $125,869,093.00. <br /> Under SI2, the Division proposes to revise the required surety at the site to $125,201,748.00. This amount <br /> includes the releasable amount issued under SL-24 on September 8,2025,and surety added under NM68.The <br /> Division currently holds a surety in the amount of$119,000,000.00.Therefore,CCC will be required to submit <br /> an additional$6,201,748.00 in bond. <br /> III. PROPOSED DECISION <br /> The Division proposes to approve SI2 and increase the required reclamation liability amount to <br /> $125,201,748.00. Any person with a valid legal interest which might be adversely affected by this proposed <br /> decision may request a formal public hearing before the Mined Land Reclamation Board in accordance with <br /> Rule 3.03.2(4). Public notice of this proposed decision will be published twice in Craig Daily Press as soon <br /> as possible. Requests for public hearing must be submitted to the Division in writing within thirty days of the <br /> first publication in Craig Daily Press. The request must state with reasonable specificity the reasons for the <br /> request and the objections to the proposed decision. If no hearing is requested within that thirty days, the <br /> Division's decision will become final. <br />