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2019-10-03_REVISION - M2018051
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2019-10-03_REVISION - M2018051
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Entry Properties
Last modified
12/27/2024 1:10:40 PM
Creation date
10/4/2019 8:00:59 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2018051
IBM Index Class Name
REVISION
Doc Date
10/3/2019
Doc Name
Adequacy Review Response #2
From
Black Mountain Sand Weld, LLC
To
DRMS
Type & Sequence
AM1
Email Name
PSH
Media Type
D
Archive
No
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4 <br /> Black Mountain Sand Weld LLC <br /> 500 Main St. Suite 1200, Fort Worth,TX 76102 <br /> (817) 698-9901 <br /> the presence or lack of an odor does not necessarily indicate the safety of a water source. As such, Black <br /> Mountain does not believe testing for odor is warranted in the baseline program. <br /> • Color-Testing for color is generally recognized as an aesthetic parameter as water with an unpleasant <br /> appearance may reduce the desirability of the water for drinking.The baseline testing parameters <br /> already include the parameters generally associated with color impacts to water, such as elevated <br /> aluminum, copper, iron, manganese and total dissolved solids. As such, Black Mountain does not believe <br /> testing for color is warranted in the baseline program. <br /> Item 5— Exhibit L Reclamation Costs <br /> Black Mountain has reviewed the provided reclamation bond estimate from the division,which contains an <br /> estimate approximately 8 million dollars higher than Black Mountain's initial reclamation cost estimate.This <br /> makes sense since the bond calculations take into account several items not included in Black Mountain's <br /> reclamation estimate: <br /> • Regrade Phase 1-The difference in costs for regrading phase 1 and topsoil redistribution are explained <br /> by the use of costs for Black Mountain to complete the work versus an outside contractor to complete <br /> the work. An outside contractor will most likely mark up the work. Black Mountain assumes the division <br /> has used costs they have previously paid for similar work as some of the items, especially equipment <br /> costs, seem to be higher than industry standard. <br /> • Establish Vegetation -The cost difference to establish vegetation varies due to the additional costs the <br /> division included for tilling and additional seed bed preparation,along with additional herbicides and <br /> herbicide application. The division also included additional costs for potential reseeding of the site and <br /> the administrative costs associated with reseeding work. <br /> • Administrative Items—Black Mountain had used a flat 5%cost for administrative items to allow for the <br /> incremental effort of managing closure work over day-to-day operations. However, the division has <br /> included costs for insurance, performance bonding, closure management, and a 10% profit margin, as <br /> well as costs for bid preparation and other administration work amounting to an additional <br /> approximately 3.5 million over Black Mountains 5%administrative estimate. <br /> Black Mountain understands the purpose of the reclamation bond and takes no issue in the difference of <br /> calculation costs. Black Mountain will post the required financial bond with the division as is required prior <br /> to the issuance of an approved permit. <br /> Item 26—Proof of Filing with County Clerk and Recorder <br /> Please see Attachment D for proof of delivery of this supplemental letter to the Weld County Clerk and <br /> Recorder's Office. <br /> Item 27—Permanent Man-made Structures <br /> As stated in the Adequacy Response Letter dated 9-12-19, Black Mountain is actively working with the <br /> communication tower owners to obtain either structure agreements or notarized no negative effect letters. <br /> Structure agreements have been sent to both American Tower Asset Sub LLC and Pinnacle Towers LLC C/O <br /> Crown Castle USA Inc. Proof of mailing and delivery of these agreements in included in Attachment E. Until <br /> such time as the structure agreements are in place or notarized no negative effect letters are received, Black <br /> Mountain will maintain a 200-foot buffer surrounding the towers. <br />
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