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The referenced Reclamation Map depicts the current topography and reclamation topography, as well as the <br />footprint of the affected area and of the reclaimed area. The act of moving dump face material up onto the top of <br />the dump is necessary due to the proximity of the toe of the current slope to the affected area boundary below the <br />dump. There is not sufficient room to doze material down the slope without exceeding the affected area boundary. <br />Your letter stated that lateral dozing would be possible, but examination of the map reveals only limited areas <br />where any material maybe placed without extending the toe of the slope. Lateral dozing can also create a <br />substantial amount of rolling and sloughing material, which also extends the disturbance beyond the approved limit <br />of the affected area. The approved reclamation plan does not allow encroaching into areas beyond the area <br />approved for disturbance. This office would consider lateral dozing as a viable method for a portion of the dump <br />slope reduction, if representative diagrams and cross sections were submitted, that show where the material will be <br />moved and the sequence of steps for moving it. Please be reminded that this office does not use equipment <br />operation costs that derive from unsafe uses or practices (i.e., operating on overly-steep slopes, etc.). <br />The Division's estimate of the volumes, haul distances, and placement locations of the moved material was taken <br />from the latest mining and reclamation maps. In preparing your responses, it may be helpful to show your ideas on <br />those same map bases. <br />7) The estimate will be revised to eliminate the use of scrapers. However, without sufficiently demonstrating that <br />the dump slope can be reduced to a 2:1 gradient, while staying within the affected area boundary, this office must <br />include the task of moving material up the slope. This office would be interested in reviewing a more cost-effective <br />method of performing this task, if one is submitted. <br />8) The uphill dozing required to attain the 2:1 slopes is necessary since the southern (uphill) edge of the affected <br />area is so close to the cut face, which will not pemut for cut and fill slope reduction. To establish a 2:1 slope will <br />require pushing material against the cut face and grading to blend the slopes to the adjoining unaffected land. The <br />maps were used in estimating this task. <br />9) The smaller grading tasks will be recalculated using a smaller dozer, such as a D6 with a ripper. Of course, this <br />change will be reflected in the mobilization/demobilization costs. <br />10) The failure rate for revegetation is ofen in the 15% to 50% range, and is backed up by years of experiences of <br />numerous operators and projects administered by the DMG Abandoned Mine Land program. Obviously, there are <br />good years and bad years for seeding reclamation sites, but it is the Division's view that a 30% failure rate for that <br />region of the state is not too high. Under optimal conditions such as deep and fertile soils with good water holding <br />capacity, sufficient precipitation, moderate seasonal temperatures and gentle slopes, the estimated failure rate is still <br />often as high as 15% to 20%. The Sunday Mine area has little to no topsoil, little to no fertility, poor water holding <br />capacity, hot and dry summers, cold and dry winters, and slopes as steep as 2:1. The Division maintains that an <br />estimated seeding failure rate less than 30% is not realistic and a lower percentage cannot be used. <br />11) The equipment ownership costs are always included in the hauling times for mobilization and demobilization <br />since the equipment is committed to a specific reclamation job as soon as it is loaded onto the flatbed to be hauled <br />to the site, and until it is unloaded back home afrer the job is completed. This cost must remain in the estimate. <br />After receiving your responses to the listed points in the paragraphs above, I will update the costs. The separate <br />reclamation task sheets will be deleted, revised or replaced as appropriate. These will be easily seen on the revised <br />summary page that will accompany the task sheets. A couple other changes I will make to the sunvnary page are: <br />reducing the costs for job superintendent time, and adding the required bond processing costs. <br />Two positive points should be made regarding the bond amount vs the actual costs of reclamation: first, an <br />operator may reduce overall reclamation liability during the life of a permit by performing regular reclamation and <br />clean-up activities, and limiting the amount of new disturbance; second, in the case of a bond forfeiture, if actual <br />