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Mr. Roy A. Karo January 10, 2006 Page 2 The discussion under INTRODUCTION, on page 1 of the appendix accurately summarizes the revegetation success demonstration requirements in effect for lands reclaimed during specified timeframes, within the Seneca II Mine permit boundary. The final sentence on page 1 states that the "youngest lands, which fall under this [permanent program] general requirement (as of September 2005), were last seeded in 1995". This statement could be somewhat misleading, because the lands included in Bond Release Block 4, which were reclaimed between 1996 and 2003, and lands in Bond Release Block 5, which have not yet been reclaimed, would also fall under the permanent program general requirements. The intent of the section might be clarified by replacing the final sentence with a new paragraph, similar to the following: It is anticipated that final bond release for lands within the Seneca II permit area will be requested under two or more applications to be submitted over a period of IO or more years. The initial application for Phase III bond release is scheduled for submittal in 2006 or 2007. The initial application will include lands reclaimed prior to issuance of the permanent program requirements (September 23, 1981), as well as lands reclaimed on or after that date. The most recently reclaimed lands to be included in the initial Phase III bond release application were last seeded in 1995. Please include the above paragraph or similar clarifying language in the Introduction section of the appendix. Bond Release Blocks are described on page 2 and delineated on Exhibit 13-13.1. In the first sentence under the Bond Release Block (BRB) section heading on page 2, there is reference to three BRB's. However, five BRB's aze listed in the section and delineated on Exhibit 13-13.1. For consistency and clarity, we request that the first sentence be amended to refer to "5ve" bond release blocks rather than "three" bond release blocks. Further, we suggest that an additional sentence be added to the first paragraph on page 2, explaining that BRB's 1, 2, and 3 will be included in the initial bond release application to be submitted in 2006/2007, while BRB's 4 and 5 will be included in subsequent bond release applications. Finally, we request that the brief description of BRB-4 and 5 be expanded, to clarify that these blocks would be subject to provisions of the Colorado Permanent Program. 3. We have several questions relating to the BRB delineations on Exhibit 13-13.1 a) There is an area of barren, eroded spoils within BRB-1, which apparently was affected by acid forming spoil material. It is our understanding that the barren azea will be excluded from the bond release block when the