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999 <br />PARCEL, MAUI3O, HULTIN & SPAANSTRA, P.G. <br />ATTORNEYS AT LIW <br />SU rtC 3600 <br />iB O~CA UEORNU STwEET <br />OENVE R. CO LORA 00 80202 <br />TELE PNONE U03129A6a00 <br />DEAN R. MASSEY TELECOwiER UO3l zssaoao <br />October 23, 1989 <br />4 }{f 3~ <br />„~ T ' ; 1989 <br />C//~~ Mli~;! <br />Ms. Catherine W. Begej -~ <br />Colorado Mined Land Reclamation Division <br />1313 Sherman Street <br />Room 215 <br />Denver, Colorado 80202 <br />Re: The Rockcastle Company <br />Grassy Gap Coal Mine <br />Permit No. C-81-039 <br />Dear Ms. Begej: <br />Enclosed with this letter you will find additional information <br />obtained by Rockcastle concerning reclamation costs for the above <br />referenced mine. Specifically, Rockcastle has obtained additional <br />information concerning the ownership and operating costs of <br />critical earth moving machinery. In addition, Rockcastle has <br />obtained additional information requested by you concerning the <br />reclamation bids previously submitted to you in support of our <br />contention that the reclamation required by the permit can be <br />performed at the site at a cost which does not exceed the bond <br />amount current y in place. <br />OWIIerShlA dnd OA0Ldt1nQ COStS. <br />In recent discussions concerning reclamation costs the <br />fundamental issue has revolved around the actual cost of owning and <br />operating a certain wheel tractor scraper. CMLRD staff states it <br />has used an industry standard cost reference guide to arrive at a <br />figure of $185.20 per hour for the Caterpillar 631E Wheel-Tractor <br />Scraper. Rockcastle has consistently maintained that the CMLRD <br />figure is drastically inconsistent with the actual costs incurred <br />in procuring such machinery for reclamation at the site. In a <br />recent meeting you indicated that you would consider additional <br />documentation regarding realistic equipment costs. <br />/_ ~ <br />