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$167,534.40), were all of the reclamation eligible for Phase I release. Rule 3.03.1(2)(d) prohibits the Division <br />from releasing any bond in excess of that required to complete remaining reclamation work required by the <br />approved reclamation plan. Accordingly, the Division has recalculated the estimate for remaining reclamation <br />tasks using current costs. The Division estimates that completing the remaining reclamation at the site by a <br />third party would cost $120,283.00. Again, this is assuming that all of the reclamation work reported to have <br />been completed by BCC is in accordance with the approved reclamation plan and deemed eligible by the <br />Division for Phase I release. <br />Attached is a table which includes each of the original reclamation tasks from the currently approved <br />reclamation cost estimate, the amount requested for release by BCC, and the Division's estimate of the amount <br />that could be released were the Phase I application approved. The figures shown as negative dollar release <br />amounts are tasks that have increased in cost since the last estimate. Increases are primarily due to rising labor, <br />equipment, and materials costs. <br />Tasks with proposed release amounts less than those proposed by the operator: <br />Tasks 2, 4, 14, and 14b: All of these tasks were recalculated to reflect the Phase I release on <br />applicable portions, but costs for the remaining work within each task were higher due to rising costs <br />for labor, equipment, and materials. <br />Task 9: The operator's request was based on all three portal seals meeting Phase I release standards. <br />However, because the sealed and backfilled main entry and beltline entry area continues to exhibit <br />slope instability, release would only be possible on the reclaimed ventilation entry. Costs to seal the <br />main entry and beltline entry have been retained, and those costs have increased due to rising costs for <br />labor, equipment, and materials. <br />Tasks with estimated release amounts in excess of the operator's request: <br />Task 5: The cost to remove the flood control dike has been removed. However, there does not appear <br />to be verification in the permit application package that the coal cars that were used to reinforce part of <br />the riverside berm are to be permanently retained. Please provide such verification and approval from <br />the landowner that the retention of the coal cars is compatible with the post mining land use. <br />Task 7b: Culvert demolition costs were researched and reevaluated in the two years since the <br />reclamation liability cost at the Bear No. 3 Mine was last estimated, resulting in a reduction in our <br />estimated removal costs. <br />Task 12: Materials costs for mulch netting have dropped since the reclamation cost estimate was last <br />done. <br />Task 18: Well sealing costs were also reevaluated, so our estimated costs for well sealing are lower. <br />As noted above, this is only an estimate of how much the reclamation liability costs might be reduced <br />if all of the work for which the release is requested is deemed satisfactory by the Division. Once the <br />Division has completed an inspection of the site and determined what reclamation work merits bond <br />release, the Division will perform an accurate cost estimate for the remaining reclamation liability. The <br />Division will also need supporting maps and volume calculations from BCC for the estimate that 56% <br />of the backfilling and regrading work has been completed on the steep slope area. <br />2