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~ ~ ~ 10/LO/9J ln:l4 n aua roozoua UJII Al.tl U4, CV qij VVL OFJS-5: 8.5 acre parcel seeded with mixture 8 in 1981; PFJ114-1: 114.1 acre parcel seeded with mixture 8 in 1981; PEK23-O: 23 sore parcel seeded with mixture 8 in 1980. The summary of the parcels indicates that some areas were seeded with different seed mixes and seeding occurred in different years. This warrants further investigation as to whether combination of these areas for the purpose of bond release is valid. First, by comparing the locations of those areas seeded with the same seed mixture by year, it is revealed that the areas seeded with mixture 8 in 1980 are not continuous, but the areas seeded with mixture 8 in 1981 are continuous. It would appear that areas OFJ8-5 and PFJ114-1 can be combined for the purpose of bond release. Under the scenario of only continuous areas seeded in the same year with tha same mix being combined, no other combinations can occur. This scenario does not take into account property boundaries of the surface owners. If only the criteria for continuous areas and similar seed mix is applied, data can be combined into three newly designated release areas; Areas 1, 2, and 3 (see Table 1). Area 1 is a combination of OEJ64-8 and OA5-4, Area 2 contains ODJ97.3, and Area 3 OFJS-5, PFJ114-1, PEK23-0. These release areas are continuous parcels within the release area. This is the minimum requirement for combining data. Again, as noted above, this does not take surface property boundaries into account. Table 2 summarizes the data if no combination of parcels were allowed and if only area OFJ8-5 and PFJ114-1 were combined and all others separate. Based on the requirement that cover and production will equal or exceed the success standard for the last two consecutive years of the liability period (30 CFR 816.116(c)(3)) and that sampling techniques for measuring success shall use a 90 percent confidence interval (816.116 (a)(2)) the allowable combinations of the six parcels in question have failed to meet Phase III revegetation requirements, II. Spoil springs Several spoil springs exist on the area to be released. A question regarding continued liability and/or monitoring of the springs was raised during the release inspection. The question presented by CYCC was that once CYCC had been released of its liability for this area, did the company have an obligation to continue monitoring the springs for data accumulation for CHIA preparation; if so, who pays for the monitoring. Also, does data from these springs become background data or used solely for CHIA preparation? OSM should Consider this question and make some policy statement with regards to CYCC as well as any future release actions. Second, does water quality play a vital role in determining eligibility for bond release? AFO may consider involving one or more hydrologists in the evaluation of this release application.