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be excessive, but when calculated using a lesser bulk factor, there might be a deficit in <br />topsoil available for redistribution to all disturbed areas. Please provide us with <br />additional information which would support PWCC's calculations and show a mass <br />balance of topsoil available for redistribution. <br />23. Revised page 13-54, Reve etg anon, says that a revegetation maintenance fee of 10 <br />percent was included for revegetation failures. We believe failure rates of 20 percent <br />for drill seeded areas and 100 percent for shrub transplant areas are more appropriate. <br />Please provide us with documentation to support PWCC's prediction of 10 percent, or <br />revise the cost estimate in accordance with our prediction. <br />24. Revised page 12-56, Production Shifts, states that PWCCs reclamation cost estimate was <br />based on two eight hour shifts per day. Research conducted by the Division indicates <br />that the average contractor would not schedule all reclamation operations two shifts per <br />day. Two shifts per day can be expected for bulk earthmoving tasks, such as backfilling <br />and rough grading, only. Tasks such as topsoil replacement, road reclamation, and <br />sediment pond removal would be performed on a single shift basis. Please revise the <br />estimate accordingly. <br />25. Revised page 12-56, Reclamation Time Frame, estimates three months for backfilling <br />grading, and topsoiling. Please revise this estimate, if necessary, after revising individual <br />task estimates as requested by the Division. <br />26. Revised page 12-56, Mobilization and Demobilization Costs. were based on mobilizing <br />12 major pieces of equipment. We could not locate a list of those, and therefore were <br />unable to corroborate this estimate. <br />27. Revised page 12-57 states that PWCC included a contingency factor of seven percent <br />of the costs in the estimate. The Division does not require a contingency fee in <br />reclamation cost estimates. <br />28. Revised page 12-57, Engineering Redesign Fee - I have enclosed a copy of the scale <br />used by the Division to determine these fees. It would appear that PWCCs estimate <br />of 5 percent is somewhat conservative. <br />29. Revised page 12-57, Contractor Profit and Overhead -PWCC estimates 7.5 percent. <br />Research conducted by the Division indicates that 10 percent is customary. <br />30. Page 12-57, Reclamation Cost Reserve Account -PWCC included this cost in its total <br />liability. This cost should not be included in the total liability, since it is considered a <br />reserve. <br />31. Table 13-1-1 of PWCC's submittal lists the labor rates used in the estimate. Those rates <br />are less than the rates accepted by the Division. I have enclosed the rates we have <br />established as a result of our research. Please revise PWCC's estimate using these costs. <br />ary en t 4 u y l, l <br />