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results of the Division's independent analyses [o the requirements of HGCC's approved reclamation <br />plan and to the regulatory requirements for Phase IUIII bond release. <br />Chronolow of Division's Review of Bond Release Application <br />In its review, the Division raised several questions resarding hydrologic impacts caused by mining. <br />The Division posed an initial set of questions in a letter dated October 20, 1998. HGCC responded <br />in a letter dated tiovember 9, 1995. The Division presented follow-up comments in a letter dated <br />December 18, 1998 and received HGCC's responses to those comments in a letter dated January 11, <br />1999. <br />The Division's independent analyses were documented in memoranda to the bond release file dated <br />December 2, 1998 (sediment yield analysis), March 2~, 1999 (analysis of ground water impacts), and <br />May 20, 1999 (permanent impoundments). <br />Comments and Objections <br />The Division received no comments, written objections, or requests for an informal conference <br />regazding the bond release application. <br />III. CRITERIA FOR PHASE II BOND RELEASE <br />Postminina Land Use and Revegetation Success <br />A Phase II bond release is allowed by those parts of Section 3.03.1(2)(b) which say, "Up to eighty- <br />five percent of the applicable bond amount shall be released upon the establishment of vegetation <br />which supports the approved postmining land use...." and "....which meets the approved success <br />standazd for cover based on statistically valid data collected during a single year of the liability <br />period." <br />The approved postmining land use of the Hayden Gulch Mine is livestock grazing, rangeland, and <br />wildlife habitat. The Division approved minimum values that must be met for final (Phase III) bond <br />release for the following four vegetation success criteria: cover, productivity, species diversity, and <br />woody plant density. Those minimum values serve as success criteria for Phase II release as well <br />because they were set high enough to support the postmining land use. Phase III release requires that <br />statistically valid data be collected in the last two consecutive years of the liability period, rather than <br />just a single year as required in a Phase II release. <br />As set fonh on page 4.15-2 of the permit application, Hayden Gulch Mine's vegetation success <br />criteria are: <br />Hayden Gulch Mine Page 4 May 25, 1999 <br />Phase II/III Bond Release <br />