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inches based upon load counts versus total topsoil volume necessary to achieve 18 inches. The Division collected two topsoil samples in the CR-93 in July 1996, as a part of the Division's topsoil verification inspection. One sample measured 9.5 inches. The second sample measured 18.5 inches. These samples do not represent a statistically adequate sample. The 9.5 inch topsoil sample likely reflects random variances of topsoil laydown depth within the parcel. Vegetation was not significantly different in the area of this shallower topsoil sample. Vegetation was relatively homogenous throughout the reclaimed parcel. The shallow sample corresponds to the outslope of a hill and reflects soil depth variability one would expect to find in an undisturbed landscape. Based upon TMI's verification of topsoil replacement thickness, and relatively consistent vegetation establishment throughout the pazcel, the Division concludes that the topsoil replacement is adequate on the CR-93 parcel. All other parcels within the two bond release blocks demonstrate compliance with the 18-inch topsoil replacement thickness, allowing for a plus or minus 2-inch variance. Reveg_etation: The post mining land use is cropland. Since the dryland hay crop is cut annually, there is no numeric cover standard. Adequate vegetative cover is necessary to control erosion. Vegetative productivity, according to Rules 3.03.1(2)(b) and 4.15.9, is the reclamation success measure pertaining to reclaimed cropland. Successful vegetation establishment is considered achieved on cropland when productivity of the reclaimed lands is 90% or greater than crop production of a suitable reference area with a 90% level of confidence. The cropland azeas for both reclaimed blocks and the approved reference area were seeded with perennial hay crop seed mixes 82-92-PHC and 94-PHC as approved in the permit. The species included in the seed mixes consist of alfalfa, mountain brome and pubescent wheatgrass. These species are approved by the Division and support the post-mining land use. TMI collected herbaceous productivity samples on the reclaimed cropland areas in July 2001 prior to cutting and baling the dryland hay crop. Herbaceous productivity on the reference area was measured in 2001 at 370.65 grams per 0.5 MZ. Ninety percent of the measwed reference area productivity equals 333.59 grams per 0.5 MZ. Herbaceous productivity measwed on the CR 82-92 block was 433.79 g/0.5 MZ. This value exceeds the reclamation standard and no other statistical analyses aze needed to demonstrate vegetation establishment success on the CR 82-92 block. The CR 93-94 reclaimed block herbaceous production measwed 329.87 g/0.5 M2. Although the measwed production value on the CR 93-44 reclaimed block appeazs slightly lower than the 90% production value of the reference area, TMI demonstrated through acceptable statistical calculations that the 329.87 g/0.5 MZ value is within the 90% standard at a 90% confidence interval. This demonstration is made on page 3 of TMI's SL03 bond release application. The Division finds that this demonstration is acceptable and the productivity standard for both bond release blocks has been achieved. Erosion Control: The November 7, 2001 site inspection of the 592.7 acres included in the Phase II bond release azea, found only one small gully. This gully was of limited length, about 50 feet long, and less than 1 foot deep. Vegetation growing in the gully indicated that this feature was old and was not actively eroding. No head cutting or sediment deposition at the base of the slope was apparent. The lack of Trapper Mine, SL-03, Findings 6 April 19, 2002