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costs, regardless of the size of the estimate, meant that the Division was underestimating these costs for <br />small sites (estimates) and overestimating these costs for large sites (estimates). This lead to a change, <br />where small estimates are charged a larger percentage for these items and larger estimates are charged a <br />smaller percentage. The percentages for the engineering cost now ranges from 10% for a $10,000 estimate <br />to 2% for a $100,000,000 estimate. The percentage for the M &A cost now ranges from 7.1% to 1.91 %. <br />Some sites saw a decrease in these costs, some sites saw an increase in these costs and some sites saw one <br />of these costs increase and one decrease. In the case of the Williams Fork Mines, they were in the group <br />that saw increases in both costs. The Division believes that these percentages provide a better estimate of <br />the engineering and M &A costs at mine sites and better ensure that the Division has adequate bond monies <br />in the event of permit revocation and bond forfeiture. <br />The Bond review comment memo indicates that the Division did not include a cost for the reclamation of the <br />Williams Fork Strip Pit and the Utah Track. Thank you for pointing that out, we will include a cost for these items <br />with the forthcoming estimate. In order to complete the estimate the items discussed above will need to be <br />addressed. In the meantime, the Division will be updating the reclamation cost estimate to the extent possible. <br />Comment Letters <br />The Division received comment letters in regards to TR36 from the Division of Water Resources and the State <br />Historic Preservation Officer. The Division responded to the State Historic Preservation Officer with additional <br />information to assist them with their review and the responded via e -mail with the final comment. The <br />correspondence from with these agencies is enclosed. <br />This concludes the Division's preliminary adequacy review of TR36. The Division is required to issue a proposed <br />decision for this revision by July 11, 2014. If you need additional time to address the Division's concerns you must <br />request an extension of the decision date in advance. In order for the Division to have adequate time to review your <br />response to the adequacy review, we request you respond to this letter by July rd <br />32014. <br />