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Tabetha Lynch, DRMS <br />Page 2 <br />February 17, 2016 <br />Please update the Redistribution of Soils Materials section of the permit to indicate that topsoil <br />replacement depths for the various disturbed areas are specified in Tables 58 to 62. <br />The Division could not locate in the reclamation plan a description of measures to be employed to <br />ensure that all debris, including but not limited to acid-forming and toxic forming materials that <br />constituting a fire hazard are disposed of in accordance with Rules 4.11.4 and 4.14.3 and the <br />description of the contingency plans which have been developed to preclude sustained <br />combustion of such materials as required by Rule 2.05.4(2)(f). Please update the reclamation <br />plan to include these descriptions. <br />Cost Estimate: <br />The last site wide reclamation cost estimate conducted for this site was with the Permit Renewal No. 6 <br />(RN6) review. Since the approval of RN6, the required liability amount has not changed. The current <br />liability is set at $4,620,949.52. Moffat County Mining currently has a bond in place in the amount of <br />$4,621,000.00. Using the RN6 cost estimate, the Division conducted an update of the reclamation cost <br />based on the most recent unit costs for equipment, equipment operators, etc. The overall reclamation <br />tasks did not change. Based on the updated reclamation cost estimate, the required liability at the site <br />should be set at $5,055,085.40. The reclamation cost estimate is attached. Given this, the permittee will <br />need to increase their surety by $434,085.40. The primary source of the increase in reclamation cost is a <br />result of the cost of revegetation. The previous reclamation cost estimate conducted for this site utilized a <br />drill seeding cost of $88.20 per acre. When the Division updated the unit costs used in our cost <br />estimating software (CIRCES) this year, the source of this drill seeding cost could not be found and it did <br />not appear to be adequate to cover the cost for this activity based on the 2015 RSMean Site Work & <br />Landscape Cost Data, 24"' Annual Edition (RSMeans), and from revegetation cost data obtained for the <br />Inactive Mines Program. Given this, the Division utilized the drill seeding cost from the RSMeans cost <br />data at $434.00 per acre. Equipment and Operator costs both increased and decreased depending on the <br />task and the equipment used with an overall net increase in costs. Details about unit costs can be found in <br />the attached reclamation cost estimate. Given this, the Division will likely need to initiate a Bond <br />Adjustment or Surety Increase revision in accordance with Rule 3.02.2(4). Please let me know if you <br />have any questions and if you would like to discuss the Surety Increase procedure. <br />• Please update Exhibit 25 with the latest reclamation cost estimate. <br />2.05.5 — Postmining Land Uses <br />2.05.5(2)(a) -(d) - No adequacy issues noted. <br />2.05.6 — Mitigation of Impacts <br />2.05.6(2)(a) -(e) <br />The following adequacy review issues where noted: <br />• The Fish and Wildlife Plan beginning on Page 2.05-35.2 of the permit does not full address <br />the items required under Rule 2.05.6(2). A number of fish and wildlife species are identified <br />