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• acreager of BK$'r and their mnrtituent $eclamation Parrelr (BP'r) are indicated on Exhibit 1, Bond Ileleare Blockr <br />~° Chmno%gical Revegetation and arrociated bond rekare block acreages. <br />BRB -1. This block would include land mined prior to August 3, 1977. These azeas were subject to <br />provisions of the 1969 and 1973 Acts that had very similar revegetation requirements. <br />BRB - 2. This block would include land mined and reclaimed between August 3, 1977 and <br />September 21, 1981. These azeas were subject to provisions of what may be termed "Interim" rules <br />preceding the formal start of provisions of the Colorado Permanent Program. <br />BRB - 3. This block would include land reclaimed between September 22, 1981 and December 31, <br />1996. These azeas were subject to provisions of the Colorado Permanent Program and aze old <br />enough to be in at least year 9 as of 2005. <br />BRB - 4 and 5. These blocks represent areas planted after 1996 and will be sampled and evaluated <br />at the appropriate time. These azeas aze also subject to provisions of the Colorado Permanent <br />Program. <br />Logical Land Management Units <br />The historical (and Euture) fences that delineate the pastures within the Seneca II Mine area were <br />established as logical land management units (for grazing putposes) prior to consideration for bond <br />release. SCC's review and interpretation of the Guidelines Regazding Selected Coal Mine Bond <br />Release Issues, Patt 2 Bond Release Area Delineation indicates that there is some contradiction <br />within the criteria/definition for the Logical Land Management Unit (LLMLJ): <br />• - Terminology <br />Lorrical Land Management Unit - `An area which may include one or more bond releare blocky, <br />characterized by uniform land ure... ". SCC's delineation meets this criterion. <br />- Bond Release Block Constraints - "...if the block canrirtr of more than one parcel, the variour pareelr mutt <br />together comprrre or be contained within a tingle logical land management unit': SCC's delineation does not <br />conform to this criterion. <br />- Logical Land Management Units - `The definition of logitalland management unit will vary depending on <br />the land ure and regionally accepted management practirer.....For rangeland orpartxreland, a management unit <br />wouldgenerally corairt oja tingle "partun"or a rural! number ofparturer utilized within a de~nedgrazing <br />ryrtem, delimited by natural orart~cxal bamierr to livertock movement...." SCC's delineation meets this <br />criterion. <br />SCC's delineation meets two of the three criteria. Based on the location of reclamation pazcels and <br />the logical location of the pasture fences, it is not possible to meet the Bond Release Block cdtetia <br />exactly. Review of the confa,*ation and locations bond release blocks (shown on Exhibit 13-]3.1) <br />indicates the complexity of assigning individual LLMU's to each contiguous group of reclamation <br />parcels. Each of the current LLMU's consist of portions of two or more BRB's. SCC will continue <br />to use the LLMU's shown on Exhibit 13-13.2 with the understanding that assessment of each BR$ <br />will consist of sampling within the boundazies of that particulaz block regardless of fence boundaries. <br />Mapping <br />• Maps to be included in the bond release application showing general location will be at a scale of 1 <br />inch = 1000 ft. Maps that depict sample locations will be at a scale between 1 inch =400 ft. and 1 <br />inch = 700 ft. Legend information on the boutdaries of Bond Release flocks (BRB's) and the <br />ESCO A.rrociater 13-13-2 TR40 * Ol /07 <br />