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Ms. Christine Johnston <br />Mountain Coal Company <br />Page 20 <br />April 14, 1997 <br />following the proposed geotechnical investigation." Unfortunately, as addressed above, <br />the Division cannot approve the proposed mine plan until an acceptable stability analysis <br />has been completed. <br />§4.0 Post-Reclamation Stability <br />The Division, as discussed at length above, continues to consider these stability analyses <br />to be unrepresentative of the actual conditions to be encountered with the reclaimed mine <br />plan configuration of the SGFA. <br />As in the case of the operational stability analyses, the Division cannot approve the <br />proposed reclamation plan until an acceptable stability analysis has been completed for <br />the reclaimed configuration of the SGFA. <br />CONCLUSION <br />In the Division's opinion, the additional geotechnical materials submitted by MCC in <br />support of its stability analyses of the operational (mine plan) and reclaimed <br />configurations within the SGFA are inadequate to cause the Division to change its earlier <br />adequacy opinion. MCC may choose to await the completion of additional site specific <br />geotechnical data with which to complete acceptable site specific stability analyses to <br />demonstrate the propriety of the proposed mine plan and reclamation plan. Alternatively, <br />MCC could choose to pursue alternative methods ofback-calculation or sensitivity-style <br />parametric stability analysis to demonstrate acceptability of its proposed plan. In addition, <br />MCC could pursue redesign or elimination of potentially high risk elements of its plan, <br />such as the switch back portion of the light use access road to the electric powerline <br />alignment. Access to the required power stanchion pads might be accomplished without <br />this intermediate segment, exposed to delineated landslide hazards. <br />72. The March 7, 1997 submittal provides an adequate discussion of which portions of the <br />proposed roads and existing roads will be removed versus retained upon final reclamation <br />of the SGFA. Although Maps 58A and 59A do not specifically detail which of road will <br />be reclaimed, the Division has no further concerns. <br />73. The Division has no further concerns. MCC's response as stated in the Mazch 7, 1997 <br />submittal is acceptable. <br />74. Map 58A is acceptable as submitted on March 7, 1997. <br />75. As it relates to revegetation and this question, the elimination of the stream relocation as <br />submitted on March 7, 1997 is acceptable to the Division. <br />