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<br />ti . ^ <br />_ United States Department of the Interior <br />OFFICE OF SURFACE MINING <br />~~"~~~"""""` RECLAMATION AND ENFORCEMENT <br />6ROOKS TOWERS <br />102015TH STREET <br />DENVER COLORADO 80202 <br />tlay 28, 1993 <br />TO: Director <br />Albuquerque Field Offica~ <br />FROlS: Chief <br />Technical Assistance Division <br />~~ <br />~~~~ <br />r <br />~~ i <br />SIIHJBCT: Technical Issues Regarding Phase II Bond Releases in <br />Colorado <br />The Western Support Center (HSC) has reviewed the information <br />provided iri the memorandum from the Albuquerque Field Oflioe, the <br />Colorado regulations and the proposed revegetation guidelines <br />dated OOtober 1988. The following are the responses to the two <br />questions rniaefl in the memorandum and as discussed in eubeequent <br />phone conversations with Bernard Freeman and Stephen 8athbun. <br />1. The first question appears to be, if physically separated <br />disturbed areas were bonded under a single bond, say they be <br />submitted for bond release as a single unit? IIndsr tIIis scenario <br />(physical separation of the reclaimed areas), the combined areas <br />could only be released as a single unit using combined data, if <br />the operator can alfirmatfvely demonstrate that the separate <br />areas represent a homogeneous population. Alternatively, the <br />operator may submit each area for bond release. As used here, <br />the tern population is defined as areas having similar conditions <br />in terms of spoil/coil quality or depth, erosional condition, <br />postmining land use, plant community, or vegetative cover. In <br />general, physically separated areas would not neat the criteria <br />necessary to demonstrate that they are a hamogeneous population <br />because of differences in overburden/root sore material, topsoil <br />quality and replacement depth, and the vegetation established on <br />the areas. If ravegatation sampling indicates significant <br />differences in the vegetative cover between the areas (ex. some <br />areas nest the sueceea standards and other do not), then it is <br />probably safe'to assume that they do not represent the sane <br />population. Given they are not the same population, then oath <br />area must be evaluated individually for bond release. Any of <br /> <br />