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In contrast, Hotchkiss Ranch conducts little, if any, comparable road maintenance activities. It <br />seems to be left up to Oxbow to repair any road damage by Hotchkiss Ranch! <br />Please note that Hotchkiss Ranch has asked that a number of the new, light use roads located on <br />their private surface not be reclaimed in the future. They have expressed interest in leaving <br />certain road segments open to facilitate their future ranching and hunting operations. To facilitate <br />and coordinate this with the Division, Oxbow anticipates a future, comprehensive TR to <br />formalize the roads to be left for future Hotchkiss Ranch postmining use versus the roads that <br />will be reclaimed. <br />Item #2 PAP Page 2.05-31 a - Degasification Well Roads. <br />A revised page 2.05-31a and 2.05-31b are included herein. Reference is made to Exhibit 2.04- <br />E3, Item 6 - Methane Drainage Well Information and Map 2.05-M1, Sheet 6 of 6 for specific <br />details of GVB light use roads in the Bear, Hubbard and Elk Creek Drainages. <br />Item #3 Reclamation Cost Estimate <br />Oxbow has a number of comments regarding the RCE as follows: <br />a. The Task 211 includes handling 11,908 bags of Portland cement grout and use of <br />368 hours of a drill and water truck at a total cost of $185,615 to plug the <br />boreholes. We suggest a more efficient, commonly used method of plugging the <br />boreholes with a cement/sand grout delivered in concrete trucks. The concrete <br />truck can simply back up to the borehole and unload. For comparison purposes, <br />Oxbow has attached a quote from Delta Sand and Gravel for such a method at a <br />lower cost of $157,850. <br />b. Task 212 notes costs associated with regrading of 23 drill pads. Please note that <br />there are 23 boreholes located on 20 drill pads rather than 23 drill pads. <br />C. Task 215 notes costs associated with replacing topsoil from stockpile to light use <br />roads. Note that the light use roads are constructed with sidecast methods and <br />there are no topsoil stockpiles associated with the light use roads. <br />Oxbow understands that additional bond will be required and we have taken steps to provide the <br />Division with a Rider to our Corporate surety. <br />Item #4 U.S. Forest Service <br />Oxbow understands we will need USFS Right of Entry for boreholes GVB-LW-'16-06, GVB- <br />LW-16-07 and GVB-LW-16-08 and associated new light use roads. We understand that the <br />current, ever evolving USFS procedures now require a review of IRA activities in the USFS <br />Washington D.C. offices. Considering the adverse effect that this USFS review process could <br />have in delaying the CDRMS approval of TR-63, Oxbow is seriously considering dropping these <br />three boreholes from TR-63. We will notify CDRMS of this decision early next week. If we <br />drop these three holes from TR-63, we would intend to follow-up with a subsequent TR <br />submittal for these three boreholes as soon as possible. Depending on the outcome of the USFS <br />review, the form of this subsequent TR may or may not be similar to the three boreholes in the <br />TR-63 proposal. <br />0 Page 2