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mining and subsequent pit backfilling proposed within PR -4 could not be completed along <br />the length of the final Wadge pits, without approval of a variance from the 180 -day time <br />frame for rough backfilling and grading following surface extraction. <br />Rule 4.14.1(1)(c) states that: <br />Rough backfilling and grading shall be completed within 180 days following coal <br />removal and shall not be more than four spoil ridges behind the pit being worked, <br />the spoil from the active pit being considered the first ridge. The Division may <br />grant additional time for rough backfilling and grading if the permittee can <br />demonstrate, through a detailed written analysis under 2.05.4(2) (c), that additional <br />time is necessary. <br />PR -4 amendments identified specific dragline final pit locations for which a variance from <br />the 4.14.1(1)(c) backfilling timeframe requirement was requested, in order to <br />accommodate highwall miner operations. The locations included 1600 feet of the Wadge <br />"ridgeline pit" to be completed by the end of 2005, and specified segments of existing <br />and future final Wadge Pits in the south extension area to be completed in 2006 and 2007. <br />The total length of final highwall to which the variance applied was 9,200 feet. <br />Based on the justification provided in PR -4 amended narrative, and the detailed timeframe <br />commitments included in the narrative and amended Exhibit 19-1A, the Division <br />approved the requested variances from the 180 -day rough backfilling and grading <br />requirement of 4.14.1(1)(c). The variances applied to the variance request areas described <br />and depicted in amended Tab 19 narrative and amended Exhibit 19-1A. With the approval <br />of PR -4, the "end of 2004" deadline for the "ridgeline pit" approved in 2004 no longer <br />applied. The variance applied solely to the timing of backfilling and grading, and did not <br />allow for more than four spoil ridges behind the pit being worked. <br />In association with PR -4, two changes were made to the Reclamation Scheduling table on <br />page 6 of Tab 19. First, the time period for Final Grading was amended to include specific <br />reference to the schedule on Exhibit 19-1A. Second, a specified time period for <br />permanent channel construction was inserted ("...within one year of completion of final <br />grading of adjacent backfill slopes..."). <br />Backfilling and grading timeframes (including variance request areas and deadlines) were <br />revised once again by PR -5, as a result of the early cessation of coal extraction, the <br />decision not to implement highwall mining, and associated reclamation plan changes. <br />Backfilling and grading deadlines for the timeframe variance areas approved in PR -5 are <br />set forth on pages 5-7 of Tab 19 of the permit application, and depicted on the amended <br />Exhibit 19-1 `Backfill and Grading Plan". The Division approved a variance from the <br />180 -day rough backfilling and grading requirement of Rule 4.14.1(1)(c), for the variance <br />areas described as: <br />30 <br />