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undesirable materials to be removed during the reclamation process. Leaving only the non-value holding scrap behind represents a reclamation liability to the State. Perhaps an agreement could be reached wherein all of the metallic materials were removed from the site by the owner /operator. This overall scrap removal operation could be funded, to the extent possible, by the sale of the value holding equipment. Removal of all metallic materials from the site would reduce the overall reclamation liability for the owner and for the State. Many factors combine to create the potential for a difficult and costly Reclamation Project. It is my overall impression that the reclamation plan for this site is poorly conceived, with little, if any, thought given to the economic completion of reclamation construction. The discontinuous nature of the operation works against efficient equipment utilization at the Roadside Mine. The resources needed to accomplish reclamation construction are poorly situated in relation to the areas requiring reclamation. This is most apparent in the lack of adequate soil resources, resulting in the necessity to create large borrow areas below the refuse piles. The amount of structural demolition, including the anticipated degree of difficulty in removing the River beltline, contribute to the overall degree of difficulty. If negotiations are undertaken for the purpose of agreeing upon a reduced cost estimate amount, I suggest that the line items for Contractor Profit, Engineering Costs, Job Superintendent, and Division of Minerals and Geology Costs be eliminated. This will result in a reduction of about $572,457 from the cost estimate. Our experience at Coal Basin indicates that these are not expenses incurred by the State when it administers a Coal Forteiture reclamation project. I was also asked to comment on the proposed dewatering plan for the South Mine. My understanding is that the current siphon system is to be replaced by angled drill hole(s) which would dewater the mine under hydraulic pressure. I agree that the siphon system should be replaced by a free draining system. However, experience at Coal Basin indicates that reliance on a small diameter drainage system is tenuous. A small blockage by foreign material will seriously compromise a small diameter drainage system. I recommend that a large diameter (three to four feet) drain be installed at the now closed mine entry adjacent to Interstate 70. A well constructed and secured, large diameter drain would be a more appropriate long term solution to the drainage problem. Not only will a large diameter drain ensure that the system will be less subject to blockage failures over time, but the cost of installation may be equal to, or less than, the estimated angle drilling costs. Cc: Dan Mathews Cheryl Linden, OAG C:lsgr\geMpccrecl