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evaluate topsoil replacement, and, in most cases, vegetative cover and species composition as
<br />required by the Regulations. Phase III or Final bond release may be requested no sooner than
<br />ten years after initial revegetation and the successful completion of the reclamation plan.
<br />MCC holds reclamation surety bonds from St. Paul Fire and Marine Insurance Company and Bond
<br />Safeguard Insurance Company (Bond numbers 40OKFO887 and 5010562, respectively) totaling $15
<br />million. The reclamation cost estimates for the reclaimed sites that will be part of the requests are
<br />covered by these bonds. The cost estimates were calculated by the CDRMS before the approval of
<br />each project's permit revision application was issued. The reclamation cost estimates include plugging
<br />the drill holes, removal of any surface facilities, regrading the area to approximate original contours,
<br />replacing topsoil, and revegetating the sites and roads. The estimates also include CDRMS overhead
<br />and contingency costs. These estimates have been subsequently updated and increased, if needed,
<br />during permit renewal and mid -term reviews, considering the most current materials, fuel and labor
<br />costs, etc. Depending on the level of reclamation actually accomplished at each site to date, as
<br />demonstrated by photographic records, as well as on -site vegetative sampling and analyses that will
<br />be conducted, MCC will request Phase I, Phases I and II, or Phases I, II, and for a few qualifying sites,
<br />a subsequent request for Phase III bond release at the percentages generally described above.
<br />MCC's mining and reclamation permit was originally issued by the CDRMS in July 1981, and was
<br />reissued August 1986, January 1993 (effective August 1991), July 1996, July 2001 and July 2006.
<br />The current five -year permit term expires July 31, 2011, and MCC has submitted a complete
<br />application for successive permit renewal. MCC's entire five -year permit area contains lands in
<br />Sections 9 -11, 13 -30, and 34 -36, Township 13 South, Range 90 West, 6 PM; and Sections 23 -26,
<br />Township 13 South, Range 91 West, 6 PM in Delta and Gunnison Counties. The area is found on
<br />the USGS 7.5 minute Somerset quadrangle topographic map. The current permit area encompasses
<br />17,154.9 acres.
<br />The reclaimed Lone Pine Gulch facility encompassed 5.5 acres and the reclaimed MDW and other drill
<br />hole sites comprise approximately 50 acres of private and National Forest System lands located in
<br />portions of Sections 14, 15, 18 -20, 22, 23, 26, 27, 29, and 34 - 36, Township 13 South, Range 90
<br />West, and Sections 1 and 2, Township 14 South, Range 90 West. The drill sites and roads were
<br />necessary for coal exploration and mine methane drainage over the past fifteen years.
<br />Reclamation was completed at the various drill site locations within MCC's permit area from 1996
<br />through 2010 and included backfilling and regrading of 50 drill hole locations and 8.5 miles of road. In
<br />addition, the sites and roads that will be considered for bond release have been revegetated using
<br />various methods of seeding, fertilizing, mulching and installation /application of straw and matting
<br />blankets. Approximately 50.0 acres have received these treatments. Reclamation of the 5.5 acre
<br />Lone Pine Gulch ventilation facility, including revegetation, was completed in May 2002. The pre-
<br />existing access road in Lone Pine Gulch will remain.
<br />If you have any questions or need further information concerning MCC's notice of Bond Release
<br />request, please contact me at 970 - 929 -2238 or Ryan Sweetwood at 970 - 929 -2308.
<br />Sincerely,
<br />Kathleen G. Welt,
<br />Environmental Engineer III
<br />cc: D. Downing, ARKL
<br />T. Kaldenbach, CDRMS
<br />D. Nolte, MCC
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