|
6.4.8 EXHIBIT H—Wildlife Information & 6.4.12 EXHIBIT L—Reclamation Costs
<br /> 13. The Division is currently reviewing technical revision 91 (TR-91) that deals with wildlife
<br /> protection fencing. The TR-91 review process will determine the appropriate changes to these
<br /> tow Exhibits with respect fencing. Any future approval of AM-12 shall not be interpreted as
<br /> changing any permit conditions being reviewed as part of TR-91.
<br /> RESPONSE: Comment noted.
<br /> 14. The updated reclamation cost summary (Tab 6) presented in Exhibit L is confusing. There are
<br /> two different numbers in red text with boxes around them labeled "Updated Grand Total"
<br /> pointing at the same AM-11 total. One is for$207,457,307, the other is $207,432,274. Both are
<br /> less than the current required bond of$207,607,502. There arefive other red text boxes with
<br /> numbers in the top portion of the table with no explanation. Tab 54a is also included as a second
<br /> page,also with red text boxes:one for"cost to reclaim 2 acres"and the other for"cost to reclaim
<br /> 4 acres", again with no explanation. Furthermore, the $25,033 and $50,066 figures from Tab
<br /> 54a do not appear to be reflected in the cost summary table. The Division would expect to see
<br /> reclamation costs for moving the Chicago Tunnel development waste in the added permit area,
<br /> as well as regrading,topsoiling and seeding for the added four acres of disturbance. For reference
<br /> the Division has enclosed the updated Surplus Tracking sheet as Table 1 showing the current
<br /> required surety as $207,607,502. Please explain your Exhibit L.
<br /> RESPONSE:Detail for Amendment 11 can be found in the original application submission and
<br /> subsequent adequacy review responses. Descriptions of the updated CC&V Reclamation and
<br /> Closure Cost Summary (Tab 6) are as follows:
<br /> • Amendment 11 updates:
<br /> o Line 4.0.3 "North Cresson Mine Area" increase from $2,726,834 to $3,081,467
<br /> o Line 4.0.4 "Main Cresson Mine Area" increase from $1,976,553 to 2,032,618
<br /> o Line 4.0.5 "Mine Area Fencing" increase from $1,188,000 to $1,250,250
<br /> o Line 15.2 "Viewshed Conservation" increase from $1,251,777 to $1,252,006
<br /> o Updated Grand Total for Amendment 11 = $207,432,274 and approved 218117
<br /> • Amendment 12 update:
<br /> o Line 4.1 "Chicago Tunnel" increase from $50,974 to $76,007. This increase is
<br /> necessary to account for approximately 2 additional reclamation acres. Based on
<br /> Assumption (4) in Tab 54a, 2 acres were originally to be reclaimed at a cost of
<br /> $25,033. Adding approximately 2 more acres for a total of four acres requiring
<br /> reclamation increases the Amendment 11 bond/warranty by$25,033. Regrading,
<br /> topsoiling, and seeding are reflected in this cost. $50,974 + $25,003 =$76,007 as
<br /> shown in the red box.
<br /> o CC&V plans to remove Chicago Tunnel development rock material as an
<br /> operational cost therefore it is not reflected in the reclamation cost.
<br /> • Bond updates:
<br /> o Amendment 11 —approved 218117 = $207,432,274
<br /> o TR88—added$5,070, approved 318117 = $207,437,344
<br /> Page 6 of 7
<br />
|