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acreages of BRB s and their constituent Reclamation Parcels (RP s) are indicated on Exhibit 1, Bond Release Blocks <br />• & Chronological Revegetation and associated Gond release block acreages. <br />BRB —1. This block would include land mined prior to August 3, 1977. These areas 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 areas 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 areas were subject to provisions of the Colorado Permanent Program and are 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 areas are also subject to provisions of the Colorado Permanent <br />Program. <br />Logical Land Management Units <br />The historical (and future) fences that delineate the pastures within the Seneca II Mine area were <br />established as logical land management units (for grazing purposes) prior to consideration for bond <br />release. SCC's review and interpretation of the Guidelines Regarding Selected Coal Mine Bond <br />Release Issues, Part 2 Bond Release Area Delineation indicates that there is some contradiction <br />within the criteria /definition for the Logical Land Management Unit (LLMU): <br />- Terminology <br />Logical Land Management Unit — An area which may include one or more bond please blocks, <br />characteritied by uniform land use... ". SCC's delineation meets this criterion. <br />- Bond Release Block Constraints — "... if the block consists of more than one parcel, the various parcels must <br />• <br />to comprise or be contained within a single logical land management unit ". SCC's delineation does not <br />conform to this criterion. <br />- Logical Land Management Units — `The definition of logical land management unit will vary depending on <br />the land use and regionally accepted managementpractices .....For rangeland orpastureland, a management unit <br />would generally consist of a single pasture " or a small number of pastuies utilitied within a definedgratiing <br />ystem, delimited by natural or artificial barriers to livestock movement.... ". SCC's delineation meets this <br />criterion. <br />SCC's delineation meets two of the three criteria. Based on the location of reclamation parcels and <br />the logical location of the pasture fences, it is not possible to meet the Bond Release Block criteria <br />exactly. Review of the configuration and locations bond release blocks (shown on Exhibit 13 -13.1) <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 BRB <br />will consist of sampling within the boundaries of that particular 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 boundaries of Bond Release Blocks (BRB's) and the <br />ESCO Associates 13 -13 -2 1840 * 01107 <br />