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Of the five respectable bids, all the companies involved are capable of performing the <br />tasks. Through customary bidding practices and policies all bids should be considered <br />and the cheapest bidder awarded the contract assuming he has adequate qualifications to <br />perform the job. For the purposes of bond calculations, it would be reasonable to assume <br />that the lowest bid in the survey may not be available and the second highest bidder was <br />accepted. <br />Tillaee <br />DMG links tillage to the planting of a stubble mulch crop. Stubble mulch may be used <br />between the time when the topsoil is replaced and the permanent seed mixture can be <br />seeded. Assuming that the stubble mulch is planted following soil placement no <br />additional tillage is necessary considering that the seed is drill seeded. The main purpose <br />for tillage is to kill weeds and to loosen the soil. Since the topsoil would be recently <br />placed, neither loosening the soil nor weed eradication would be necessary eliminating <br />the need for the tillage beyond that achieved by the drill. <br />The unit costs for tillage are also too high. First, a shallower disking depth is required for <br />seedbed prepazation. See the attached contractor survey for data specifically addressing <br />the Deserado Mine acreages. <br />Seeding Costs <br />DMG uses costs for seeding that are reportedly from contract data. These values appear <br />much too high to include only the seeding portion of the operation and not other tasks or <br />materials. Of obvious concern is the cost reported for broadcast seeding. At a unit rate <br />of nearly $180 per acre, excluding escalators such as profit, insurance, mob./demob., etc., <br />this is way out of line with realistic costs. See the attached contractor survey for data <br />specifically addressing the Deserado Mine acreages. <br />Mulching <br />While mulching is discussed within the permit it is not required except in large steep <br />areas. <br />The contractor survey conducted by BME showed that DMG's unit costs for stubble <br />mulching was too high. The supporting data is attached. Please make appropriate <br />adjustments to the unit costs. <br />a. Seed Prices <br />DMG apparently is using seed prices off of published price lists from several vendors. <br />This data reportedly dates back to 1999. Price lists are not representative of <br />competitively bid prices. Substantial discounts are given off the list prices from the <br />vendors listed. <br />7anuary 15, 2003 9 Permit Revision #4 Comments <br />Blue Mountain Energy, Inc. <br />