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III IIIIIIIIIIIIIIII <br />GRAND VALLEY COAL COMPANY <br />P.o. Box 70 <br />Loma, co~orado sisza-0o7o <br />(970) 858-3608 FAX (970) 858-7690 <br />January 26, 1998 <br />Mr. Dan Mathews <br />Division of Minerals & Geology <br />2148 Broadway; #C-5 <br />Grand Junction, CO 81503 <br />Re: McClave Canyon Mine, CO-80-004 <br />MR -25 Reclamation Costs <br />Dear Mr. Mathews, <br />Grand Valley Coal Company has reviewed your letter of January 22, 1998 <br />regarding reclamation costs for the shop addition, MR•25. Grand Valley makes the <br />following comments and is submitting the following responses to the Division's <br />review. <br />1. The division does not agree with the documentation provided by Grand Valley in it's <br />estimate of the reclamation of the concrete floor. The cost of demolition and disposal of <br />the floor as calculated by the Division is $1,482.00. Grand Valley believes that these <br />costs are higher than the actual cost to demolish the floor but will agree to bond at the <br />Division's higher cost estimate. <br />2. Grand Valley has revised Page 29 of Table 3.7-1 to include cost of disposal of the shop <br />building. <br />3. The title of the Foreman has also been revised to Lead Laborer on Page 29. <br />Grand Valley disagrees with the Division's interpretation that the existing building <br />must be "demolished and disposed of before the "reclamation credits" associated <br />with MR - 25 could be applied". The Division is charged with the responsibility to <br />ensure that the reclamation bond posted by the operator will be adequate to reclaim <br />the disturbance. Previous reclamation cost estimates by the Division have been in <br />error because of the Division's insistence on using "Means". Grand Valley has always <br />disagreed with these estimates. At this submittal, evidence that the Division's <br />estimate was incorrect was presented. Grand Valley is not asking for reclamation <br />credits. It is only asking that the calculations for reclamation costs be corrected <br />based upon the evidence presented. Since only the calculations are being corrected <br />Grand Valley believes it is unnecessary to demolish the building. <br />