2008-07-11_REVISION - C1992080 (2)

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l Savage and Savage Environmental practical solutions for environmental issues 4610 Haystack Drive 970 674 8080 telephone Windsor, Colorado 80550 970 674 8088 facsimile savageandsavagegearthlink.net JUL 11700a July 10, 2008 piv Mi6i °t an d Sa ety n, Mining Tom KaldenbaclY Colorado Division of Reclamation, Mining & Safety 1313 Sherman Street, room 215 Denver, CO 80203 RE: PAR response for Permit Renewal (RN03) for the Oakridge Energy, Inc. Carbon Junction Mine (CDRMS file C-92-080): CDRMS Bond Calculation Dear Mr. Kaldenbach: Thank you for forwarding the Division's revised bond calculation for the Carbon Junction Mine renewal (RN03). I appreciate your clarification of the calculation by addition of the column, Applicable amount not vet bond released. Overall, the calculation reflects the final reclamation that was accomplished in 2006. The revised bond amount reflects a 60 percent reduction in the calculated value of the original reclamation bond tasks, yielding a direct cost value of $295,461.00, and a total reclamation bond of $377, 723.00. At this point I would like to reserve comments on the bond calculation per se and direct my comments to a concern that we briefly discussed in the past, but that continues to affect bond calculations at the Division. In the Regulations of the Colorado Mined land Reclamation Board for Coal Mining, Rule 3.02.2 Determination of Bond Amount it is stated in relevant part, "The amount of the performance bond required shall be adjusted for good cause as affected land acreages are increased or decreased or when the cost of future reclamation changes including the cost of abating any violation for which a notice of violation has been issued. The Division shall review the amount of bond required for a permit area and the terms of acceptance of the bond at the time permit reviews are conducted under 2.08.3 or every two and one-half years, whichever is more frequent...