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Mr. Ross Gubka, P.E. <br />Western Fuels-Colorado <br />February 9, 2007 <br />Page - 5 - <br />f. Wyoming includes a 4% contingency cost. <br />2. WFC questions the Division's estimated volume for the 631 scraper. Edition 34 <br />of the Caterpillar Handbook, upon which the current edition of our estimating <br />program is based, lists a heaped capacity of 31 cy heaped and 21 cy struck for the <br />631 G scraper. The new edition of the handbook lists heaped and struck capacities <br />of 34 cy and 24 cy. We will update the program and the New Horizon estimate <br />accordingly. <br />WFC also disagrees with the Division's approach of using an average of struck <br />and heaped volumes for each load. Our loading times aze based on an average <br />struck/heaped volume and would have to be increased if we assumed that the <br />scraper would load to full capacity, so the gain in payload would be offset by <br />cycle time. This issue has been reseazched by the Division in the past, when we <br />contacted several earthmoving contractors and described a surface mine <br />reclamation scenario (state contract, independent contractors, etc.). We were told <br />that basing estimates on average loads was a reasonable assumption, thus we are <br />satisfied that this approach is sound. <br />3. WFC states that it "has issues with the whole concept of figuring topsoil handling <br />cost that has been completed. Furthermore, using made up average haul distances <br />is a poor estimating technique." The issue of topsoil replacement costs will be <br />handled in Technical Revision 55. We did notice that page 8 of the Wyoming <br />Guideline states that "lands that have been topsoiled and seeded but have no bond <br />release must be bonded for retopsoiling, scarification, and revegetation." <br />WFC is also concerned about the topsoil haul distances. The Division agrees that <br />"made up" haul distances would be a poor estimating technique. The Division <br />estimates haul distances based on actual distances between topsoil stockpiles and <br />distribution areas, using the "centroid to centroid" approach. Additional <br />information on the topsoil haul distances used in the Division's cost estimate is <br />available if you would like to look at it. A review of the Wyoming Guideline <br />indicates consistency with the Division's practice on estimating costs for <br />previously distributed topsoil. The guideline states that the "haul distance and <br />grade used would be the weighted average used for the rest of the reclamation." <br />After WFC submits the maps for its upcoming Phase II Bond Release application, <br />the Division will revise its cost estimates for all remaining topsoil replacement <br />tasks, and will verify that the haul distances are accurate. <br />4. The issue of irrigation will be resolved with Technical Revision No. 55. <br />5. WFC suggests the use of Wyoming DEQ Guideline No. 12 for reclamation of <br />drill holes and monitor wells. For many yeazs the Division has estimated drill <br />