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<br />Mr. Fortes[ Luke <br />February 20, 1998 Page 2 <br />Comment 23 (10/6/97 letter) <br />Response accepted. The Division had erroneously assumed that the required replacement depth <br />was 14", and so did not recognize the built in consolidation factor. It is also appropriate for <br />Trapper to omit the additional 5% factor that had been inadvertently added by Trapper. The <br />revised topsoil costs are now acceptable as submitted. <br />Comment 24 (8/21/97 letterl <br />Response accepted. Since we made this comment, the Division has been in contact with <br />equipment rental agencies regarding this issue. They verified that rental equipment has an <br />operation meter, which does not start until the equipment is operating. No ownership costs are <br />incurred during transportation. <br />Comment 26 (8/2l/971etter) <br />Response accepted. DMG estimated costs based on our drill time recommendations, and our <br />estimate was compazable to Trapper's average time estimate. <br />Comment 29 (8/21/97 letterl <br />Response accepted. Since Trapper has revised the regrading volume figures, the bulking factor is <br />apparent. Since the previous estimates were considerably lower, it did not appear possible that a <br />bulking factor had been applied. <br />Comment 30 (8/21/97 letter) <br />You indicated that costs for revegetation were applied to all areas for which Phase II bond <br />release had not been requested. In accordance with Section 3.03.1(3)(a) of the Rules, the <br />Division is required to retain bond which would be sufficient for a third party to cover the cost of <br />reestablishing revegetation at any time during the liability period. Therefore, Trapper needs to <br />post bond for revegetation costs on all areas which have not been fully released from liability. <br />Please revise the revegetation costs accordingly. <br />Comment 31 (8/21/97 letter) <br />Response accepted. DMG had not intended to imply that Trapper should include 6 weeks of <br />maintenance per year. Reference to an existing operation was used simply to illustrate a point. <br />Comment 34 (8/21/971etter) <br />Response is accepted, but please incorporate your response into the permit application package <br />so that in future reviews it is apparent that the requirements of Sections 4.03.1(7)(a)(ix) and <br />4.03.2(7)(a)(ix) have been addressed. <br />