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volume within the <br />competed basin. Since <br />the basins won't be fully <br />developed for 25± <br />years, some <br />consideration for time <br />should be considered, <br />which the Varra <br />Companies estimate <br />attempts to perform <br />based upon 25 percent <br />exposure over a 6.25± <br />year time frame. <br />Extraction that is not <br />phased is still bound by <br />time and demand, and is <br />reflected in the original <br />Varra Companies <br />estimate, but in fairness, <br />did not identify the <br />division in years, making <br />the calculation less clear <br />to the reader, and a <br />communication fault. We <br />hope the explanation <br />helps remedy this <br />consideration. <br />The per unit costs for <br />discharge came to <br />$0.000249 per gallon, or <br />significantly more than <br />the Western Sugar unit <br />cost. In addition to <br />significantly higher <br />volume of discharge, <br />Part of this may also be <br />attributed to calculated <br />`inflow volume per hour' <br />reported at 143,268.21 <br />gallons per hour. The <br />volume accordingly to <br />be 2,846,115.46 <br />cu.yds. or <br />574,801,478.08± <br />gallons of water total. <br />Since the exposed <br />area takes time within <br />a 30 year life of the <br />mine, full extraction <br />would occur in apx. 25 <br />years. When the total <br />volume of possible <br />discharge is divided by <br />4, this means it would <br />take 6.25 years to <br />affect 25 percent of <br />the volume area, and <br />the parcel would be <br />overbonded for this <br />category during this <br />time period for the <br />potential <br />143,700,368.52 gallons <br />of water if discharge <br />stopped. <br />The Varra Companies <br />estimate utilized the <br />per unit costs derived <br />in the Western Sugar <br />estimate of $0.000026 <br />per gallon. Since unit <br />costs determined by <br />OMLR were used, <br />values utilized at the <br />time in CIRCES are <br />embedded in the unit <br />price logic utilized, <br />where the values were <br />similar. Some values <br />were not similar <br />Varra Companies, Inc. Coulson Resource Project OMLR M- 2013 -064 6 <br />Correspondence to Peter Hays 23 March 2014 <br />