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III. OBSERVATIONS AND FINDINGS 1. Topsoil Replacement Although depth of topsoil is carried under the Phase II work description, depths of topsoil were verifted, and cost liability was released, under the two previous bond releases (SL-O1 approved 10/08/1987 and SL-02 approved 04/27/1998) for the areas of this bond release. The findings of these two previous bond releases aze included herein by reference for replacement of topsoil. Colowyo provided topsoil replacement depth sampling information with their second bond release application (SL-02), submitted September 25, 1997. SL-02 requested a partial Phase I bond release. Since Phase I bond release requirements apply to backfill and grading activities, and do not include topsoil replacement as a criteria, the Division included a discussion of the topsoil replacement but did not release liability for the completed work. Please refer to Colowyo's SL-02, partial Phase I bond release application, received 9/25/97, for [he topsoil replacement data. Please reference the Division's SL-02 Findings document, dated April 27, 1998. The Division concluded that the topsoil replacement depths meet permit requirements on 712.1 acres of reclamation in the East Pit, West Pit and Section 16 Pit areas reclaimed between 1982 through 1996. Exhibit 1 of the 1997 partial Phase I bond release • application and Exhibit 3 of the 2000 partial Phase II bond release application were compazed for areas requested for release. The Division found that the area requested for 2000 paztial Phase II bond release corresponds with the 1997 partial Phase I bond release area and the topsoil sampling data. 2. Revegetation The areas of this bond release were seeded in 1986 through 1995 (see Exhibit 3 and Table 1 page 3 of the Application). Approved seed mixes (PAP Table 7 page 2.05-44) were drilled into prepared seedbeds (PAP pages 2.05-44 and 2.04-53). Seeding was accomplished during fall time periods (Application page 3 and Division monthly coal partial and coal complete, and annual bond compliance, inspection reports on file at the Division). The method of estimating cover is described on page 9 of the Application. In general, the procedures recommended in a guideline published by the Division were followed (PAP page 4.15-5). Detailed procedures were coordinated with the Division prior to collection of data. A grid system was created to randomly select points on the reclaimed areas. The center points of Fifteen randomly-selected cells were located by Geographic Positioning System equipment, from which 50-meter transects were selected in random directions. "First hit" data was collected at'/~-meter intervals (lowering of pins) along the transect line. Field data was collected on July 19 and July 20, 2000 for the Sagebrush reference area, on July 21 through July 25, 2000 for the Mountain Shrub reference azea, and on July • C-81-019, SL-03, 15 August 2001 Page 6 of ] 0 Pages