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The bond liability period for revegetated areas in Colorado is a minimum of 10 years. The liability period for underground workings need only continue for the duration of mining operations and a reasonable time period thereafter to include full subsidence effects since these areas usually are not revegetated. The Division tnay release the bond or reclamation liability for the underground workings only after all mining in the area is completed and rite major subsidence effects, if any, have been manifested. For areas of extraction, the liability period shall be a minimum of three years after mining. These time frames may be adjusted on a case by case basis, based on subsidence monitoring data, depth of cover, extraction methods, topography, [and use, and other relevant information. The liability time frame shall be addressed to the extent possible during the permit review and prior to permit issuance. /f revegetation is required because of subsidence damage, the operation would be bound to the liability period for revegetated lands as contained in Rules 3.02.3 and 4.15.7(5). A[[ requests for bond release or release of reclamation liability shall be processed in accordance with Rule 3.03. Until a release has been approved, these lands shat! remain within the approved permit boundary. The Division shall make written findings in regard to whether such areas shall be released from fiability. OBSERVATIONS AND FINDINGS Industrial Land Use Areas All industrial land use areas were inspected within the last 9 months. Each of the sites south of Highway 12 were inspected on June 17, 1998, as were sites GE-72-93, GE-76-94, NW-3-4-95, GE- 73-93, and the 3rd North Intake. Generally, sites are level pads accessed by, or immediately adjacent to roads. Pad size is typically 75' X 75'. Numerous sites have topsoil stockpiles to be utilized upon final reclamation under Rules promulgated by the Oil and Gas Conservation Commission (OGCC). Erosion problems were not observed. All sites have approved API numbers assigned through the OGCC. The Division considers the industrial activity has commenced once an API number has been assigned, even though some of the industrial sites remain inactive due to efforts by the gas company to maximize gas production and quality. As shown on Map 18 submitted with the application, Apache Canyon Field Golden Eagle Mine- Rig t of Way -Degas Wells and ads, roads which access these sites are included in the bond release request, although these roads will continue to be utilized by the surface landowner for access to the property. Roads were found well maintained and in very good condition during the inspection. Much of the road system was pre-existing, especially south of Highway 12 and used for gas extraction, prior to and during, coal mining operations. Generally, gas gathering pipelines are buried adjacent to road corridors. Drainage patterns at the main facility site are modified by the permanent road and the railroad tracks, both of which bisect the disturbed area of the mine. Culverts which remain at the site are necessary to route water under the roadways and the railroad tracks at numerous locations. The drainage control system, including ditches and culverts, which are necessary to route water to the sediment ponds and to route clean water around and through the revegetated area, are specifically excluded from this bond release and remain the liability of BRI to maintain and repair, as necessary, until final bond release. The drainage control system is shown on Map 13-B, Site Reclamation Plan. 4