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Bond Release Insaection The Division conducted a bond release inspection on October 20. 1999. The site was inspected in accordance with Section 3.03.2(2). Forrest Luke and Karl Koehler represented Trapper. Tom Kaldenbach represented the Division, Randal Pair represented the Office of Surface Mining, and Rob Emst represented the Bureau of Land Management. The bond release parcels are on land owned by Trapper Mining Inc. and the State of Colorado. Although the State Board of Land Commissioners was notified of the inspection, no one from that agencey attended. Technical Review Following the bond release inspection, the Division reviewed technical aspects of Trapper's bond release submittal in order to determine if Phase Il bond release is warranted. The review evaluated the methods that Trapper used in gathering and processing the data in the bond release submittal. The review considered the technical validity of conclusions presented in the submittal. Those conclusions were then compared to the requirements of Trapper's approved reclamation plan and to the regulatory requirements for Phase II bond release. Adequacy Questions and Responses No adequacy issues resulted from the Division's review of Trapper's submittal. A gully was found during the bond release inspection on parcel D-AB-95 (see the inspection report for a description). Trapper repaired the gully a few days later. The repair would not re-initiate the 10-year bond release liability period because the repair was done in the first five years of the period as allowed in Section 4.15.7(5). The parcel was seeded in 1995. Comments and Objections The Division received no comments, written objections, or requests for an informal conference regarding the bond release application. III. CRITERIA AND SCHEDULE FOR PHASE II BOND RELEASE Postminine Land Use and Reve2etation Success A Phase Il bond release is allowed by those pans of Section 3.03.1(2)(6) which say, "Up to eighty- Five percent of the applicable bond amount shall be released upon the establishment of vegetation which supports the approved postmining land use...." and "....which meets the approved success standard for cover based on statistically valid data collected during a single year of the liability period." For a Phase II bond release occurring prior to a Phase III (final) bond release (as in the current bond release), the Division evaluates the bond release vegetation for its progress toward supporting the post-mining land use upon final bond release. Trapper Mine Phase II Band Release Page 3 12/23/99