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BME provided a 2002 price quote from Granite Seed for the specific seed mixes and quantities required by the reclamation plan. Granite Seed is a major distributor for reclamation seed in the western US with facilities closest to the Deserado Mine of any of the major distributors. As such, the prices quoted are indicative of the current seed market with competitive bidding specific to the seed mixes required for the Deserado Mine and should be used for bonding calculation purposes. What was proposed by BME is the best information available to DMG and should replace the outdated inaccurate data currently used. a-e. Remaining Unit Costs DMG stated that many of the unit costs were based on a 1986 DMG Contractor Survey. This survey is 16 years old and probably only referenced one project size. BME recommends that a new survey be conducted with other variables such as overall project size. Smaller projects generally command a much higher unit costs than larger projects due to increased administrative time per unit. Consideration must also be given to adjusting for the assumptions of profit, insurance, administrative costs, etc. tacked on to the task job costs by the CIRCES program. Not properly addressing these factors leads to improper use and abuse of the data. BME conducted a revegetation contractor survey specifically addressing the task and acreage for the Deserado Mine in October 2002. A summary along with copies of the survey forms is enclosed for your records. This data should be used for bond calculation purposes since it represents the most accurate and task specific estimation of unit costs available. 13. Cleaning Sediment Ponds RP-1, 2/3, 4, and Sa Two Times Data (beyond worst case) was supplied showing that these ponds would not need to be cleaned following reclamation of the refuse areas. If DMG does not consider the initial conditions at the time of reclamation, with recently disturbed soil, no vegetation, no soil consolidation, etc. for the entire duration of the model as "worst case" please provide a reasonable description of "worst case". DMG is correct in stating that the ponds should be maintained at the time of initial reclamation if warranted. However, additional pond cleaning and equipment mobilization afrer this time will not be needed even under what we would consider "worst case" scenarios. If DMG would like us to look at other scenarios which you view as more representative please provide us with these scenarios such that we may provide you with models to your liking. The "three-year" sediment load scenario does not hold for these ponds. Much greater sediment holding capacity exists. Using only the recently disturbed characteristics at the time of reclamation results in calculated cleaning intervals of 260, 41, 64, and 34 years for these ponds respectively assuming they are cleaned to their original state. January 15, 2003 10 Permit Revision #4 Comments Blue Mountain Energy, Inc.