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Permit Number: C1982057 Page 7 of 20 <br />Phase III <br /> <br />Adequacy Review <br />Adequacy questions were provided to SPL on 26 February 2025 regarding well transfers, and permanent sealing <br />of wells. Well abandonment reports are on file electronically for the site at DRMS here: <br />https://dnrweblink.state.co.us/drms/search.aspx <br />Wells WWC25 and WSC25 were requested to remain and be transferred to the landowner. Both wells were <br />transferred to the landowner from SPL and permitted by the Colorado Division of Water Resources on 28 <br />August 2025. <br /> <br />II. CRITERIA and SCHEDULE for BOND RELEASE <br /> <br />The Division evaluated Seneca Coal Company's request for final phase I/II/III bond release on 107.9 acres in the <br />SL8 application. Under Colorado's Permanent Program, the process of releasing the reclamation bond for a mine <br />site is explained in Rule 3.03 and further described in the Division's 1995 Guideline Regarding Selected Coal <br />Mining Bond Release Issues. The bond release process involves three phases and for this bond release all three <br />phases were requested. <br /> <br />Phase I Bond Release Rule 3.03.1(2)(a) states: <br />"Up to sixty percent of the applicable bond amount shall be released when the permittee successfully <br />completes backfilling, regrading, and drainage control in accordance with the approved reclamation <br />plan." <br /> <br />The Division's Guideline Regarding Selected Coal Mine Bond Release Issues dated 18 April 1995 outlines what <br />the Division may use to evaluate reclaimed lands proposed for Phase I bond release. Evaluation will be based on <br />the specific requirements of the reclamation plan and the functional requirements of the post-mining land use. <br /> <br />Phase II, Rule 3. 03. 1( 2)( b) states: <br />“Up to eighty- five percent of the applicable bond amount shall be released upon the establishment of <br />vegetation which supports the approved postmining land use and which meets the approved success <br />standard for cover... based on statistically valid data collected during a single year of the liability <br />period". <br /> <br />And, regarding Phase II bond release, Rule 3.03.2( 3)( b) also states: <br />“No more than sixty (60) percent of the bond shall be released so long as the lands to which the release <br />would be applicable are contributing suspended solids to stream flow or runoff outside the permit area in <br />excess of premining levels as determined by baseline data or in excess of levels determined on adjacent <br />nonmined areas". <br /> <br />At Phase III, Rule 3.03.1(2)(c) states that: <br />the final portion of performance bond, "shall be released when the permittee has successfully completed <br />all surface coal mining reclamation operations in accordance with this approved reclamation plan, and <br />the final inspection procedures of 3.03.2 have been satisfied. This shall not be before the expiration of <br />the period specified for revegetation responsibility in 3.02.3." <br /> <br />