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<br />• 23. PWCC has not experienced seeding failures that would justify <br />even a ten percent failure rate. Discussions with other <br />northwest Colorado operators indicate their failure rates are <br />also low. What basis does the Division have for justifying a <br />20 percent failure rate for seeded reclaimed areas in <br />northwest Colorado? Mines in northwest Colorado have good <br />quality topsoil, for the most part, and normal precipitation <br />levels are quite adequate for vegetation establishment and <br />growth. It is true that establishing shrubs is more <br />difficult, but a 100 percent failure rate seems excessive. It <br />would appear to indicate an ad infinitum planting effort. <br />Again, does the Division have a sound basis for a 100 percent <br />failure rate? The Soil Conservation Service specifies a 50 <br />percent survival estimate for dryland woody plantings. <br />Planting rates for the shrub and the tree planting areas are <br />2000/acre (Table 13-6 and Table 13-5-1). This is 1000 stems <br />more than the 1000 stems/acre density standard specified for <br />concentrated planting areas. PWCC feels that the 10 percent <br />failure rate for seeding areas is reasonable, as is a 50 <br />percent failure rate for planting areas. Page 13-54 and Table <br />13-5-1 have been modified to clarify the 10 percent failure <br />rate for seedings and 50 percent failure rate for plantings in <br />bond release calculations. <br />24. The Seneca Mine currently conducts a number of operations on <br />a two- and three-shift basis. Operating only one shift a day <br />inflates the equipment costs by as much as 27 percent. In the <br />interest of resolving the bonding comments, PWCC has revised <br />the estimate as suggested by the Division. <br />25. The time frame has been revised on Page 13-56. <br />26. The mob and demob costs have been revised. Please see <br />Worksheet MOB-i. These amounts are largely taken from the <br />Division's mob and demob costs for H&G Loadout. <br />27. The contingency fee has been dropped. <br />28. The Engineering Redesign Fee has been revised per the <br />Division's Contract Preparation Fee figure. Based on the new <br />Direct Cost, the fee is 3.9 percent. <br />29. The economy has caused some contractors to cut their profit <br />margin to below the rule of thumb of ten percent. In the <br />interest of resolving this estimate, PWCC has revised the <br />profit to ten percent. <br />30. This cost was entered as a liability due to the fact is was <br />being used as a "draw" on future liability items, i.e., small <br />disturbances, roads, etc. This cost has now been eliminated <br />from the calculations. <br />• <br />