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9/30/2014 State.co.us Executive Branch Mail -Re: FW: Moffat County Mining, LLC -Williams Fork Mines, TR14 -36 Technical Adequacy Response II Pack... <br />COLORADO <br />Re: FW: Moffat County Mining, LLC - Williams Fork Mines, TR14 -36 Technical <br />Adequacy Response II Package and Request for Extension <br />Ebert - DNR, Jared <jared.ebert@state.co.us> Mon, Sep 29, 2014 at 7:58 AM <br />To: "Nettleton, Jerry" <JNettleton @peabodyenergy.com> <br />Cc: Mary Rodriguez - DNR <mary.rodriguez @state.co.us >, Alysha Hernandez - DNR <br /><alysha.hernandez @state.co.us> <br />Jerry, <br />I have extended the decision dates for TR36 to October 17th and RN6 to October 31 st. I will review the concerns <br />raised about the cost estimate. In regards to the indirect costs, could you please specify which specific indirect <br />costs you feel are incorrect? <br />Thank you, <br />Jared <br />On Sun, Sep 28, 2014 at 10:20 AM, Nettleton, Jerry <J Nettleton @peabodyenergy.com> wrote: <br />Jared — <br />Attached are the components of our second Technical Adequacy Response for TR14 -36 (fourth response for <br />Permit Renewal RN 13-06) except for the associated revised maps. The full submittal package (including <br />maps) follows via mail. Please note that I have attached a Certificate of Insurance (Exhibit 1) specific to Moffat <br />County Mining, LLC, but have also included a copy of the prior Certificate, as responsive to the specific <br />Technical Adequacy comments and our responses. <br />Review of the updated bonding calculations initially raised concerns due to the apparent increase from <br />09/06/13 (Jim Stark calculations) to 08/06/14 (Jared Ebert calculations) of approximately $629,000. More <br />detailed review, however, indicated that most of this increase was due to inclusion of costs for reclamation of <br />the Williams Fork Strip Pit and the Utah Tract (approximately $422,600 + $134,000 indirect costs) in the <br />updated cost estimate. We are concerned that the CDRMS has progressively increased the individual <br />components of indirect costs to the point where indirect costs total approximately 32 percent, when compared <br />with direct costs. This amount is excessive, is not representative of actual indirects for typical large earthwork <br />contracting, and should be reviewed and adjusted to a more practical and realistic level. <br />We would also ask that you review continued inclusion of the following structures which have been removed <br />from the site or fully reclaimed (approximate costs including concrete footings and pads shown are from most <br />recent estimate), as they do not represent any ongoing liability and the CDRMS has previously eliminated <br />similar structures from liability estimates, and accepted a corresponding bond reduction request: <br />Mine Office - $340 <br />VP /GM Office — $340 <br />Engineering Office - $340 <br />https: / /mail.google.com /mail /u /0 / ?ui= 2 &ik= e29129fcb5 &view =pt &search = inbox &th =148cl l>4f6b l4d5cl &siml =148cl b4f6b l4d5cl 1/3 <br />