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>remove the pertinent tasks (38,and portions of 39 and 40) in the <br />>reclamation cost estimate? Would the revision be considered a "bond adjustment" <br />>revision, not subject to the requirements of a bond release? <br />>In such a technical revision addressing "bond adjustment", would the <br />>Division consider revising the bond calculations for the tasks that <br />>have been completed, for example, all the final reclamation work done <br />>in 2006? It is still our reading of the statute and regs that the <br />>Division has no obligation to perform work that has already been <br />>successfully conducted (and liability released under Phase I), <br />>therefore, there is no reason for the Division to hold reclamation bond monies for such <br />work. <br />>We believe that Division is not recognizing the difference between <br />>reclamation bonding and reclamation liability. Is this a topic that <br />>would be best addressed by the Board in a Request for Declaratory Order? <br />>In my brief review of the bond recalculation, I noted that there are a <br />>number of assumptions that are not correct. For example, in tasks 31a <br />>and 37a (hauling topsoil to reclaim the sediment ponds), the material <br />>is described as "Decomposed rock-50o Rock, 50% Earth". This is not a <br />>correct characterization of the material in the topsoil stockpiles and <br />>certainly affects the productivity of the machinery and subsequently <br />>inflates the calculated costs for these tasks. I would suggest that we <br />>meet to discuss these issues prior to issuance of the final Division <br />>bond recalculation and findings for the renewal. <br />>If you could provide the Divisions thoughts on the above, it would help <br />>guide our decisions. Thanks <br />>Mike Savage <br />3