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• ~ge 7 <br />June 18, 1985 <br />Sand Pit <br />C. Farrell <br />to accept their offer. On other operations we have acquired rather <br />significant quantities of very suitable soils just by this means. In <br />the rapidly growing area of Colorado Springs, this possibility is <br />certainly not far-fetched, but on the other hand committing to it would <br />be quite foolish. <br />Exhibit L - Reclamation Costs <br />Item 1 - The estimates provided assume the "worst case situation:. <br />The following considerations would make the situation even worse; please <br />detail these costs and include in a revised "TOTAL ESTIMATED COST": <br />a. Backfilling to an average depth of approximately 20 feet (as <br />illustrated in the "Sand Pit Cross-Sections: Existing vs <br />Reclamation") over the entire affected area; and <br />b. mulching over entire area, if not presently included in the <br />revegetation estimates. <br />RESPONSE - We wish to point out that the backfilling proposed in <br />the plan is to be done with part of the wastes produced by the <br />processing of sand at the Daniel's Sand Pit #2 plant to the south. This <br />waste is a fact of processing and is a result of mining. To propose an <br />even worse situation than what you have presented let us assume that no <br />waste is produced. Then there will not be anything to backfill with and <br />the 20 feet of fill would have to be hauled in. Of course, we hope that <br />you understand that if that possibility were very likely then <br />backfilling would not even be proposed as part of the reclamation. If <br />the Division or the Board wishes operators to bond backfilling with <br />wastes produced as part of the mining and/or processing then we would <br />venture to say that few operators could afford to propose such an <br />expensive process. If we cannot backfill with wastes produced by the <br />operation itself without having to bond perhaps 3/4 million cubic yards <br />of waste produced over two or three decades then we believe such a <br />requirement is contrary to the intent of the reclamation law that mined <br />land be reclaimed in a most environmentally and economically compatible <br />fashion. <br />Looked at another way, if backfilling did not occur then there <br />would be an additional amount of 2.5:1 slope that would need to be <br />graded. We have presented a figure of $500 per acre for slope grading. <br />If an additional amount should be added then that amount should not be <br />for 20 feet of backfill over about 25 acres but rather for slope grading <br />of that area of slope that would be exposed in the event backfilling did <br />not occur. With a 2.5:1 slope and a depth of 20 feet, the additional <br />slope amounts to about 2.5 acres. We would therefore agree to an <br />additional amount of $1250 bond to cover the estimated cost of grading <br />this additional slope. We would also agree to an additional amount of <br />