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1 <br />1.0 Introduction <br />1.1 Purpose of the letter – Steep-Slope Mining Variance Request L Pit and Ash Pit <br />The Regulations of the Colorado Mine Land Reclamation Board for Coal Mining (Effective August 30, <br />1990 as modified through September 14, 2005) (Regulations) allow for a variance from the requirements <br />to restore reclaimed mine areas at surface coal mines to approximate original contour (AOC). A variance <br />may be granted for areas of steep slope coal mining if the requirements of Section 2.06.5 are met along <br />with the performance standards of Rule 4 including specifically Rules 4.14, 4.16 and 4.27.4. Steep slope <br />mining is defined as any slope more than 20° or such lesser slope as may be designated by the Board or <br />Division after consideration of soil, climate, and other characteristics of the region. <br />The following discussions are designed to provide information to the Division of Reclamation, Mining and <br />Safety (Division) that operations at the Trapper Mine in the L Pit and the Ash Pit meet the requirements <br />for steep slope mining under Rule 2.06.5 and allow the Division to find that a variance from approximate <br />original contours for these areas is appropriate to promote a long-term stable postmining land surface <br />and that the post-mining topography improves the overall watershed and meets the postmining land use. <br />The proposed post-mining topography is shown in plan view on Map M12 Sheets 2 and 3 and in cross <br />section on Map M14A Sheets 1 and 3 included with this submittal. The variance request does not <br />change the methods being used at the Trapper Mine for backfilling and grading, topsoil replacement or <br />revegetation as described in Sections 3.2, 3.5, and 3.6 of Permit C-1981-010. Nor does the variance <br />affect the post-mining land use as discussed in Section 3.0 below. <br />Along with the following summary discussion, more detailed information is provided in the attachments <br />and revised pages for Permit C-1981-010, new Section 3.5.3.1. This document is intended to be inserted <br />in Appendix B of the Permit C-1981-010 document and is referenced as such in the Section 3.5.3.1 <br />pages. <br />1.2 Regulatory Background for Steep-Slope Variance and Required Information <br />A variance from the requirements of AOC for steep slope mining areas is allowed by the Regulations as <br />long as certain demonstrations can be made relative to the mining and the reclaimed surface. These <br />demonstrations include information on the nature of the steep slope mining, reclaimed slopes and overall <br />stability of reclaimed surfaces, and information to demonstrate that a reclamation variance will still allow <br />the reclaimed area to meet certain conditions. The sections of the Regulations where needed information <br />is identified are Rule 2.06.4, Rule 2.06.5, Rule 4.14, Rule 4.16, Rule 4.27.4. Table 1 provides a <br />summary of the requirements and a cross reference to where these are discussed in the proposed <br />changes to the Trapper Mine Permit C-1981-010. <br />