2014-03-26_PERMIT FILE - M2013064

• Permit No: M2013064
• IBM Index Class Name: PERMIT FILE
• Doc Date: 3/26/2014
• Doc Name: Second Adequacy Review Reply Comments
• From: Varra Companies, Inc.
• To: DRMS
• Email Name: PSH
• Media Type: D
• Archive: No

Grading
Soil Demand
Revegetation
Concurrent grading is
anticipated for the
location and similar to
other operations, should
consider that overall
costs are nearly identical
to the Western Sugar
location which estimated
40 -45± foot limitations
to overall basin depths,
whereas the mean depth
for Coulson is estimated
at 40± feet.
We believe your estimate
for soil replacement
costs of $3,586.48 is
within reason.
The primary difference
of this cost is related to
the use of mulch. We've
established the use of
hybrid cover crops in
lieu of ineffective mulch
applications and related
methodology in an area
prone to Chinooks. The
OMLR has accepted this
practice for reasons
stated in the application.
We believe when the
costs are removed for
labor, materials,
equipment, etc. for the
The estimate for the
same reclamation
methodology and walls
was $38,791.28
determined by OMLR
for Western Sugar, and
$220,918.40 for
Varra - Coulson.? A
difference of
$182,127.12 dollars
more? Our original
estimate for Western
Sugar, iterated for the
identical conditions at
the Varra - Coulson
Project was $
46,272.82, which we
will retain to offer the
OMLR the benefit of
the doubt.
No additional
comment.
It should be
understood that the
revegetation area for
Western Sugar of
34.23± acres is
approximately 520
percent larger than the
6.58± acres pending
total revegetation at
the Varra Coulson
parcel. The OMLR for
Western Sugar
estimated a
revegetation cost
there of $13,977.39, or
166 percent more for
Varra Companies, Inc. Coulson Resource Project OMLR M- 2013 -064 9
Correspondence to Peter Hays 23 March 2014