2022-02-23_PERMIT FILE - M2021059 (13)

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TO: %Ir. Peter MIN s Date: Febri miA ,l 20'1' Pa-e 10 ZI 6.4.12 Exhibit L - Reclamation Costs Comment 26 The Division calculated the cost for an independent contractor to reclaim the site based on the information submitted by the Applicant in the application and the Division's requirement to include the cost to backfill the exposed groundwater until the final augmentation plan is obtained from the DWR at $3,018,000,00. A copy of the Division's bond estimate is attached for review. Response 26 Our request, which we discussed, is the opportunity to put up a place holder bond between the time of DRMS/MLRB approval and actual mining. The largest component of the bond is for backfill of the first 5 acres of mining Cell 1 of$2,420,000. For a placeholder bond, LRM offers a placeholder value to replace the backfilling of$300,000. This is the amount estimated by LRM's legal counsel for the augmentation plan water court process. Thus, the requested placeholder bond would be approximately$394,000 as summarized in Table 1: Minor comments or questions on the bond include: • The job superintendent rate seems high. The RS Means (013113200260) average rate for a superintendent (with location adjustment to Greeley, Colorado) is $2,325 per week, before O&P. • Under Revegetation Work for C 1 Shoreline, C 1 Wetlands, and Access Road, weed control spraying application is double counted (under Tilling and under Mulching and Miscellaneous Application) • 3 trucks are listed under "roadable" equipment in Mob/Demob but only 2 are listed in the other sheets 6.4.13 Exhibit M - Other Permit and Licenses Comment 27 Please commit to providing copies of all required and approved permits and licenses to the Division, when available. Response 27 LRM commits to providing copies of all required and approved permits and licenses to the DRMS as they become available. 20220209_1045_DRMS Adequacy_Reviex Response_MASTE R.docx TELESTG