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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />February 9, 2007 <br />Page-4- <br />"1" Round Commeuts on DRMS Reclamation Cost Estimate" December 28, 2006 <br />General Comments <br />1. WFC suggests the use of the Wyoming DEQ Guideline No. 12 in determining an <br />appropriate correction factor for bulldozer productivity. The Division has <br />developed a program called CIRCES (Colorado Integrated Reclamation Cost <br />Estimating System) that we have been using for many yeazs in Colorado, and <br />more recently is being used by other state programs. The CIRCES program <br />requires site specific information to estimate costs for each permitted operation. <br />Costs used in the CIRCES are updated annually. Correction factors (material <br />consistency, dozing method, spoil pile grading tazget, grade, altitude, material <br />weight, etc.) aze derived from site specific information and compared to <br />descriptions of job conditions in the Caterpillaz Performance Handbook. This <br />reference is widely accepted as an accurate estimating tool in the mining and <br />construction industry. Comparisons of estimated costs using the Division's <br />program have been favorable to actual work contracted by the Abandoned Mined <br />Land (AML) Program within the Division. <br />Occasionally, the Division has accepted costs based on the Wyoming Guideline in <br />other operator's reclamation cost calculations. In those cases, the Division noted <br />that the costs using the Wyoming Guideline were equal to or greater than those <br />generated by the Division (using our methods). <br />If the Division were to consider using the Wyoming DEQ Guideline, several <br />additional considerations need to be addressed. We noted that Wyoming includes <br />several indirect costs that the Division does not and that were not discussed in <br />your letter. Those include: <br />a. On page 11 of the guideline, Wyoming includes a flat $200,000.00 <br />redesign fee. The Division uses a percentage of the total costs, which is <br />derived from the 2006 edition of the Means Sitework and Landscape Cost <br />Data publication. <br />b. Wyoming assesses 1 % for preconstruction investigation and stabilization. <br />c. Wyoming assesses 0.5% for monitoring programs. <br />d. Wyoming assesses $200,000.00 per yeaz of the project final reclamation <br />and reclamation liability for site security and liability insurance. <br />e. Wyoming assesses a minimum of $250,000.00 for long-term <br />administration and accounting costs. <br />