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I. PROCEDURES AND SUMMARY OF THE REVIEW PROCESS <br />Honeywood has applied for Phase II bond release under the Colorado Surface Coal Mining and <br />Reclamation Act following reclamation of the Hamilton Mine. The mine is located approximately <br />2.5 miles southeast of Naturita, Colorado, more specifically described as follows: <br />Township 46 North, Range 15 West, N.M.P.M. <br />Section 32: E %2 E %Z <br />Section 33: W %2, Disturbed areas in the S 1/2 NW 1/ NE 1/, <br />SE 1/ NE 1/, W 1/2 NW 1/ SE 1/ <br />Township 45 North, Range 15 West, N.M.P.M. <br />Section 4: Portions of Lots 3, 4, 5, 6, 11 & 12 <br />Section 5: N %2 NE % NE 1/ <br />The permit encompasses 757 acres, 111.2 acres of which have been disturbed. The disturbed area is <br />comprised of 90.2 acres which were backfilled, graded, topsoiled, and seeded, and 21.0 acres of <br />"permanent facilities", including ponds, ditches and haul roads. Mining operations began at the <br />Hamilton Mine in March 1992, and ceased in July 1993 when the coal supply contract with the <br />power plant located in Nucla was not renewed. Coal was mined from two separate areas within the <br />permit: Mining Area No. 1 located to the west, encompassing approximately 73 acres, and a 9.9- <br />acre portion of Mining Area No. 3 to the east. Mining Area No. 2 was permitted, but never mined. <br />Backfill, grading, and redistribution of topsoil were completed in 1992 and 1993. Seeding was <br />accomplished in 1993 for the 90.2 acres that that had been reclaimed, including the facilities area. <br />The entire reclaimed area was reseeded in 1995, and a third seeding (of 80 acres) occurred in 1998. <br />SL-1 granted Phase I bond release for the entire permit area, exclusive of sedimentation ponds and <br />collection ditches. SL-1 was approved on August 10, 1994. <br />The SL-2 application for Phase II bond release was received by the Division on November 2, 2009. <br />The application was deemed complete on December 18, 2009, after the Division received proof of <br />publication of the applicant's public notice. Honeywood published notice of the bond release <br />application in the San Miguel Basin Forum once weekly for four consecutive weeks, beginning <br />November 5, 2009. Honeywood also notified land owners within and adjacent to the mine permit <br />area, and other interested parties, of the application for bond release, as required by Rule 3.03.2(1). <br />No comments, written objections, or requests for an informal conference regarding the bond release <br />application were received by the Division. <br />The Division reviewed the SL-02 application following the completeness determination, and issued <br />an adequacy letter to Honeywood on May 27, 2010. Significant adequacy issues included the need <br />for 1) a revised revegetation study that would fulfill the requirements for statistical adequacy, and 2) <br />proposed details of the area weighting procedure to be used for comparison of reference area data to <br />reclaimed area data. <br />The Division scheduled and conducted a bond release inspection on June 3, 2010. The site <br />inspection was conducted in accordance with Rule 3.03.2(2). The inspection was not held within 30 <br />2