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Objection to DRMS' Surety Increase Request <br />January 14, 2016 <br />Page 5 of 5 <br />and computerized scale system — and a mere fraction of such salvage value will far <br />exceed the perceived `cost' of removing the improvements now sited within the Quarry. <br />ii. The backfilling that the approved Reclamation Plan requires for all of the various <br />benches within the Quarry (i.e., the production benches, the process bench, and the mill <br />bench) either occurs on a continuous basis (as is the case for the production benches) or <br />has already substantially occurred (as is the case for the process bench and the mill <br />bench) - or MSHA wouldn't permit us to continue to operate. Accordingly, all of the <br />volumetric and cost calculations related to these various tasks (i.e., Tasks 02a, 03a, 03b, <br />04a, 04b) in the past 4 years have been materially erroneous, and should be re-evaluated. <br />iii. Most, if not all, of the topsoil application, distribution and placements estimated <br />in the November 2011 Surety Increase assumed either a limitless amount of topsoil at site <br />(which is erroneous), or assumed that Ca1X (or any successor operator) would import the <br />required amounts of topsoil onto the site — which neither Ca1X nor any successor <br />operator is or would ever be required to do, under the approved Reclamation Plan. <br />We are confident that when the requested re-evaluation of the required Surety Amount <br />for our Quarry has been completed — taking account of all pertinent provisions of the <br />long -approved Reclamation Plan — that we will be entitled to a substantial rebate. <br />Respectfully submitted, <br />al, <br />Peter Babin, <br />Chief Executive Officer, Ca1X Minerals, LLC <br />Copy, by e-mail: Ms. Pauline Adams, BLM Field Office in Silt <br />Mr. Russ Means, DRMS <br />