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<br />handling and storage of all overbtuden. Section 2.05.4(2)(c) requires the application to <br />contain a plan for backfilling and grading in accordance with 4.14. Section 4.14.2(1)(6) <br />requires backfilling and grading to the most moderate slope possible, not exceeding the <br />angle of repose or such lesser slope as necessary to achieve a factor of safety of 1.3. <br />Certain slopes shown on Map 2.05.4-1 aze quite steep, and may present stability concerns, <br />as well as reclamation concerns. For example, the area immediately adjacent to and just <br />west of Fill 5 has a slope angle of 33° (1.5h:1v), and a slope length of 200 feet. The azea <br />within the "1999" blue lines that will lie between Fill 1 and Fill 4 has a slope angle of <br />22° (2.48h:1 v), but a slope length of 400 feet and a southeast aspect. <br />The Division recommends the applicant redesign the slopes of the non-fill areas at the <br />surface mine so that south, southeast, southwest and west-facing reclaimed slopes are no <br />steeper than 3h:ly, that all other non-fill reclaimed slopes be no steeper than 2.Sh:ly, and <br />that the construction (material transportation, segregation, backfilling, compaction) of <br />these slopes will meet the 1.3 factor of safety required by Section 4.14.2(1)(6) of the <br />Regulations. Please provide this information. <br />68. In this same paragraph, it is stated that "a maximum of 1500 linear feet of pit will be <br />open at any one time. A variance is requested for the first cut through the ridge as it will <br />be lefr open for the second phase of the surface mine...". <br />It is assumed the performance standazd for which the variance is being requested is <br />Section 4.14.1(1)(a) of the Board's regulations. This section discusses the need for rough <br />backfilling and grading to follow coal removal by not more than 60 days or 1500 linear <br />feet. However, this standazd applies solely to contour mining, and does not apply to <br />mountaintop removal mining. <br />If Lorencito Coal Company wishes to apply for a variance from this standard for its <br />proposed contour mining operations, it should be more specific as to how much of a <br />variance it is seeking: an extra 60 days, or an extra 60 months? An extra 1500 linear feet, <br />or an extra 15,000 linear feet? <br />69. It is stated on page 2.05-10 (1st paragraph) that "a solid berm will be left along the <br />outcrop to keep material from going down slope". Please provide the dimensions of this <br />berm, ensuring its dimensions are sufficient to satisfy the requirements of Section <br />4.26.2(2) of the Board's Regulations. <br />70. Section 2.05.3(2)(x) of the Regulations requires the applicant to provide a "detailed <br />timetable sufficient to describe the various mine phases proposed by the applicant". The <br />regulation goes on to state that "the maximum acreage proposed for each phase of the <br />operations within the permit area must be specified." Please provide this timetable. <br />71. Sections 2.05.3(5), 2.05.4(2)(d) and 4.09.1(4) of the Regulations require a discussion of <br />how topsoil will be removed, segregated, stored and redistributed. <br />Under "Hollow Fill Construction", on page 2.05-10, there should be a discussion of how <br />