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well permits, they don'[ need to remain permitted by DMG. While I could see an azgument for disagreeing with Colowyo on this point, I can also see how these thirteen wells could go through the process of being [ransfered to the landowner as described in Rule 4.05.14. 12. Colowyo, in its TR-50 application cover letter, states that some of the drill sites being transferred to the NOI "lie within 5-yeaz permit azeas and do not need to be reclaimed". I would somewhat disagree with this statement. Technically, Rule 4.07 requires all holes (except blast holes) be "plugged, sealed, or otherwise managed". Mining through boreholes could be considered "otherwise managing" these boreholes, and as such, could be considered a form of reclamation. Additionally, Colowyo could construct a drill site in or near a pit, and drill a borehole to a coal seam situated deeper than the seam being mined at the time. As such, we would need to bond for the reclamation of the portion of the borehole that extended below the pit floor (Rule 4.07.2). I think it would be best, in both instances, to bond for the reclamation of the borehole, and require the operator to maintain the bond until we can observe the borehole sealed, mined through, or reclaimed. If we agree that this is the policy, we should ensure that this is so stated in Colowyo's permit. 13. Colowyo, in its TR-50 application cover letter, states that only 16 of the sites within the permit remain in "bond in place" status. I disagree. With the exception of the 13 West Pit Fill drill sites, all the sites approved under the MRs, plus the 13 sites covered by the 13-site bond, still have bond in place for them. DMG did not "float" any monies from unused drill sites to other sites. 14. Some of the coal exploration MR applications discussed the building of a vaziety of access roads. When we transfer the drill sites to the NOI, we should transfer the associated access roads as well.