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In November of 1987, in conjunction with a Settlement Agreement pertaining to Permit Renewal
<br />RN-O1, the Division and P&M agreed that the "Permanent Program Bond" should be increased
<br />from $2,631,945 to $7,121,196. In December of 1987, P&M submitted a bond rider
<br />accomplishing this.
<br />In June of 1988, the Division approved Technical Revision TR-15, which described a
<br />reclamation plan for the "South of Shop Slide". The Division required a $50,520 increase in
<br />reclamation bond, which P&M accomplished by submitting a rider to the "Life of Mine Bond"
<br />on July 5, 1988 that increased the bond from $20,000 to $70,520.
<br />On November 11, 1989, P&M submitted Bond Release Application SL-O1, requesting release of
<br />the $20,000 portion of the "Life of Mine Bond" being held for gully stabilization in the azeas
<br />subject to the 1983/1984 bond release request. On June 28, 1990, the Division approved this
<br />request, granting a release of $20,000. In July of 1990, P&M submitted a rider to the "Life of
<br />Mine Bond" reducing the amount from $70,520 to $50,520.
<br />On March 8, 1996, P&M submitted its application for Permit Renewal RN-03. On June 19,
<br />1996, P&M submitted its application for Bond Release SL-02, requesting a Phase I bond release
<br />in the West Ridge and Center Ridge areas. On June 11, 1997, P&M submitted an application for
<br />a self-bond. On September 14, 1997, P&M submitted its application for Bond Release SL-03 for
<br />areas in East Ridge (Phase III) and Center Ridge (Phases II and III) for the South of Shop Slide
<br />azea (Phases I, II, and III} (this application was subsequently withdrawn on November, 9, 1997,
<br />and re-submitted on October 19, 1998 as Bond Release application SL-OS).
<br />On September 16, 1997, the Division proposed to approve P&M's application for Permit
<br />Renewal RN-03. The Division Findings Document states "The Division currently holds a
<br />$7,171,716 reclamation performance bond for the Edna Strip Mine. The current reclamation
<br />liability is $7,171,716. Reclamation liability for the disturbance in the West Ridge and Moffat
<br />Areas is $7,121,196. Remaining liability for the South of Shop slide area is $50,520. The South
<br />of Shop area was reincorporated into the permit boundary in 1988, following a slope failure on
<br />previously lands in 1984." It is this $7,171,716 bond amount, composed of the $7,121,196
<br />"Permanent Program Bond" amount and the $50,520 "Life of Mine Bond" amount, that the self-
<br />bond application amount (approved in February 1998 for the amount of $7,171,716) and bond
<br />release amounts associated with Bond Release Applications SL-02, SL-04, SL-O5, SL-06, and
<br />SL-07 are based upon. The $7,171,716 bond amount is also the bond amount that Table 1 in this
<br />Findings Document is based upon.
<br />Submittal of Bond Release Application and
<br />Completeness Determination by the Division
<br />The Division received P & M's bond release application SL-8 on September 11, 2003, and found
<br />the application complete on October 6, 2003, after the Division received proof of publication of
<br />the applicant's public notice. The completeness determination was made in accordance with
<br />Section 3.03.2(1)(d).
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