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NEWMONT <br /> 6.4.11 EXHIBIT K- Climate <br /> DRMS Comment(italics): <br /> The Erhihit is adequate us submitted. <br /> Newmont Response: <br /> Comment Acknowledged. <br /> 6.4.12 EXHIBIT L - Reclamation Costs <br /> DBMS Comment(italics): <br /> 48. Section R. In the Summary of'EYhihit L the.lpplicant states the financial warranty./or reclamation <br /> has been estimated to S 196.350,--2 (please note. the Exhibit L reclamation cost estimate summary <br /> table totals the bond cat S19?,-6,124). .4M--13 proposes to expand VLF?, therefore it is assumed <br /> there will he an increase in the reclamation cost for the site regarding the additional grading, <br /> rinsing detoxification, storm water drainages, and revegetation associated with the increase si.Je oj' <br /> VLF3. Please explain how the .4pplicant is proposing to increase activities with .4.11--13, but is <br /> estimating a reclamation cost estimate less than the current financial warranty set for the site <br /> IS208,531,301t. <br /> Newmont Response: <br /> In the past,the financial warranty, estimates have been submitted as a full life of mine build out and <br /> associated calculation. As discussed and verbally approved by DRMS during the October 8`' 2019 <br /> Amendment 13 review meeting, CC&V proposed a methodology that closely aligns with the requirements <br /> of the Act and Rule by providing a Financial Warranty estimate that reflects the actual current cost of <br /> fulfilling the requirements of the reclamation plan and environmental protection plan in a given year. In <br /> Exhibit L of Amendment 13, CC&V committed to providing a prorated financial warranty calculation to <br /> DRMS annually. This financial warranty calculation will forecast actual closure liability approximately 14 <br /> months out from the date the estimate is submitted. This approach is consistent with the incremental <br /> bonding approach previously, used by CC&V and accepted by DRMS and is consistent with the <br /> C.R.S.I 17(4)(b) and Rule 4.2.1(4). The financial warranty estimate has been developed to support this <br /> approach. The $193,095,473 represents the actual current cost of fulfilling the requirements of the <br /> reclamation plan and environmental protection plan at the end of 2020. CC&V believes this methodology <br /> provides an opportunity to collaborate with DRMS, thus refining the financial warranty calculations, <br /> increase transparency, and mitigate risk to both parties. <br /> DRMS Comment(italics): <br /> 49. Liabiliq,Percentage. The reclamation cost estimate summary table includes a Liability Percentage <br /> column which ranges,from -781% to 80.91°o,for total direct cost of certain tasks and 9.1%for the <br /> majority of the indirect costs. 6fhen totaling these discounted tasks, the Division approximates this <br />