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Technical Review <br />The Division reviewed technical aspects of P & M's bond release submittal in order to determine <br />if the requested bond release is warranted. The review evaluated the methods that P & M used in <br />gathering and processing the data in the bond release application. The review considered the <br />technical validity of the conclusions that P & M presented in the application. The Division also <br />independently evaluated various hydrologic impacts. The Division then compared P & M's <br />conclusions and the results of the Division's independent evaluation to the requirements of <br />P & M's approved reclamation plan and to the regulatory requirements for bond release. <br />Chronoloav of Division's Review of Bond Release Application <br />The Division received the SL-09 application on December 9, 2004. The Division on December <br />10, 2004 requested changes to P&M's proposed public notice of the application. Proof of <br />publication of the public notice was received at the Division on January 24, 2005. The Division's <br />review of P & M's bond release application found the application, with one exception, to be <br />technically adequate as submitted. P & M was advised on December 30, 2004 that a discrepancy <br />was noted, during the review, that the addressees of letters sent by P & M to advise owners of <br />land adjacent to the permit area of the bond release application differed from the map of <br />landowners in the Permit Application Package (PAP). P & M revised the map to update the <br />ownership information by a minor revision (Number 42) to the PAP. Minor Revision 42 was <br />approved on February 23, 2005. With a letter to an adjacent land owner identified in the revised <br />list, letters of notification had been sent to all current landowners within and adjacent to the <br />permit area as of February 23, 2005. Within that time frame, the Division acquired, on February <br />3, 2005, a copy of the Routt County Conditional Use Permit PP2004-053 that accommodated the <br />industrial postmining land use of the approved reclamation plan. <br />The Division conducted an analysis of P & M's hydrologic impacts. The analysis covered data <br />cited in the bond release application and P & M's past annual hydrology reports. <br />The Division received no written objections, or requests for an informal conference, regarding <br />the bond release application. <br />III. CRITERIA FOR BOND RELEASE <br />Phase I Bond Release <br />Section 3.031(2)(a) states, "Up to sixty percent of the applicable bond amount shall be released <br />when the permittee successfully completes backfilling, regrading, and drainage control in <br />accordance with the approved reclamation plan." <br />Phase II Bond Release <br />A Phase II bond release is allowed by those parts of Section 3.03.1(2}(b) which say, "Up to <br />