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the approval of the Irrigated Pasture reference area as the standard creates a perception of WFC <br />changing the rules to suit it's reclamation results. It can be seen clearly, from the sequence of events <br />along with discussions with DRMS staff that this was not the case. WFC pursued the IP reference area <br />for the same reason that DRMS wanted it: it was the most scientific and accurate method of <br />determining revegetation success. DRMS, at no point since the IP reference area and reclaimed areas of <br />SL-12 were first studied in 2007, indicated that these studies could not be used in a bond release <br />application once the IP reference area was approved. If DRMS had informed WFC that the studies <br />needed to be conducted after the approval of the reference area, then WFC would not have studied the <br />reclaimed areas in 2007 and 2008. Only the reference area would have been studied in 2007 for TR-55, <br />due to the great expense of a reclaimed area vegetation study. <br />WFC, like all mines in Colorado, depends on DRMS to provide guidance in both the permitting and <br />reclamation process. While aware of the regulations and rules that guide mining, WFC has frequently <br />sought out the Division's opinion and judgement on various aspects of the reclamation process <br />especially when making significant changes to the reclamation success standard such as switching to a <br />reference area from a technical standard. At no point did WFC attempt to manipulate the state <br />reclamation rules, or deceive DRMS in any way in order to successfully achieve bond release. <br />Therefore, WFC believes that there is no reason to deny the Irrigated Pasture Phase 3 bond release <br />applied for in SL-12. <br />