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Cost Estimate Review Comments 1. Shifts Per Day While we recognize DMG's desire to maintain many levels of "conservatism" a single 8-hour shift for a project of this magnitude is unreasonable and inconsistent with standazd working practices of the construction industry. The only time construction crews work short hours such as these is when the labor force is local, the project of relatively short duration, and the contractor is short on work. A contract of this magnitude would warrant two shifts per day or longer shifts (6 10-hr shifts or 5 12-hr shifts per week) even if work were scarce. 2. Job Efficiency vs. Utilization Primedia, the publishers of the "Cost Reference Guide for Construction Equipment" were again contacted to verify the proper use of their cost data. This time they were less supportive of their prior claims. After several inquiries they concluded that the "efficiency hour" did not directly relate to "operating hour." Some of the deductions for an "efficiency hour" may be deductible from the "operating hour" but these aze more operator/contract specific and beyond the detail of the cost data. 3. Snoil Pile Correcfion Factor DMG's azgtunent to retain the "spoil pile" factor as currently used relies on the perception that material is being placed in lifts consistent with an engineered fill. While under certain circumstances this approach may be beneficial, the consistency, structural characteristics of the fill material, hydrologic characteristics of the site, and post-mine land use do not warrant such practices. Even surface mines where much deeper fill is replaced along highwalls lifts aze rarely used. A prime example is the placement of spoil with draglines or the end-dumping of waste rock in a classic valley fill. Even if fill was replaced in lifts the correction factor used by DMG is excessive and improperly applied. Considering material placement in 2' lifts the added push distance would only be an additional 15'. This equates to about a 110 LCYlhr reduction for a 100' push (9%) or a 40 LCY/hr reduction fora 250' push (7%). In addition, efficiency is gained by not pushing over a highwall (per the description in the Cat Handbook) from the aspect that the dozer would not have to approach the end of its push with such great care as not to overshoot the highwall. Thus, cycle time would be effectively reduced given the same push distances of an angle-of-repose slope. DMG further attempts to justify the use of a "spoil pile" factor by claiming additional time to check grade to ensure drainage. For reclamation back to natural conditions little extra time is needed to check grades and drainage. This is usually the task of the forman and not the operator. Furthermore, DMG has already applied this aspect of inefficiency to the `job efficiency" factor and should not attempt to apply additional deductions for the same aspect of a job. The emphasis of reshaping of the reclamation at the Deserado Mine is to blend the reclaimed area with the surrounding topography. To best achieve this goal the final grades must be looked at as more of an art form than an engineered January 15, 2003 4 Permit Revision #4 Comments Blue Mountain Energy, Inc.