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Mr, Rich Atkinson - 4 - May 12, 1987 <br />.,, , <br />8. On page 2.05-70, elimination of the wildlife habitat improvement ~~ <br />program is proposed. However, based on the objectives of the ~~~ <br />program, the Division feels that additional discussion is warranted <br />prior to such elimination. In particular, the objective of drawing <br />wildlife away from shrub seedlings on the reclaimed area would seem <br />to remain important at this time. I believe that discussions <br />between Colowyo, the Division, and D014 should be initiated to review <br />this proposal further. <br />Rule 3 - Bond <br />1. The operator must provide a rider to the bond which incorporates the <br />language of Rule 3.02.4(2)(b)(c)(A&B). <br />2. The Division has reviewed the request for bond release contained in <br />the application. The operator requests Phase I release for a 226 <br />acre area. Rule 3.03 specifies that a maximum of 60% may be <br />released under Phase I, however the operator is requesting an 85% <br />release. The Division cannot accept the rationale for this amount <br />of release, which in effect requires 100% release for backfilling <br />and grading, and 60% release on the remainder of the bond. Such <br />release would not be in compliance with the regulations. There are <br />however, several possible scenarios for obtaining additional <br />release. <br />a. The first possibility is to reouest Phase II release for the <br />area in Question. I have enclosed a memorandum which discusses <br />the demonstrations necessary for Phase II release. I believe <br />this area may be sufficiently revegetated to achieve the <br />requirements for Phase II. <br />b. The operator could show that the original bond for the area <br />could be lowered, based on current costs and changes in <br />operations plans. If the original costs are lowered, the <br />retention of 40% would also represent a smaller amount of money. <br />c. Another method which could be used to show lower original costs <br />is to revise the original backfilling and grading estimates for <br />the Streeter Fill portion of the area proposed for release. It <br />may be possible to show that the backfilling and grading costs <br />associated with the fill are less than those associated with <br />the pit, thus lowering the original estimate for this area. <br />Without any changes in the bond release reouest, a maximum of 60% <br />may be released. This would result in retention of E861,669.00 for <br />this particular area. <br />3. The Division has reviewed the bonding calculations for the next <br />5-year term. The assumptions made with respect to worst-case <br />analysis are well described and are accepted by the Division. <br />Volume estimates are also accepted. The following are Division <br />concerns which must be addressed prior to approval of the <br />calculations. <br /> <br />