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Mr. Dave Berry Coal Program Supervisor Division of Minerals and Geology Page 2 equipment. This equipment otherwise would have been dedicated to reclamation activities, but instead had to be shared with the highwall mining project to improve the sustainability of that operation. It now appears the highwall miner will not be able to perform at an acceptable level, and the project may have to be abandoned. Thus, the sharing of equipment to prepare any new areas would not be necessary, and the equipment can be redirected to the reclamation effort. SCC will discuss this situation in greater detail with the Division at our meeting on Thursday, October 28`". The focus on developing and implementing innovative, economical, and productive mine plans to adjust to the deteriorating coal reserve configuration has not been totally successful in sustaining coal production targets. The efforts to extend mine life resulted in delayed reclamation efforts, corrective action on outstanding violations, and other routine compliance activities. We assure the Division we have no intention of avoiding our responsibilities to rehabilitate the mined lands. The labor situation at the mines has compounded the situation both in terms of reduced efficiency and inability to recruit experienced personnel. Above normal absenteeism, underachievement, and overall poor attitude have directly impacted SCC's ability to sustain production while completing reclamation in a timely manner. In addition, SCC has faced extreme difficulty in finding and retaining qualified operators and mechanics. Many prospective new hires are not willing to accept employment knowing the longevity of the mines is in question. The resulting undermanned work force has contributed to SCC's inability to complete reclamation and compliance activities in a timely manner. During the September 23`', 2004 DMG meeting, SCC indicated that we were looking into hiring outside contractors to spread topsoil during the fall of 2004 and add contract personnel for permitting purposes. SCC has since been informed by the Union Local that the UMWA Labor Contract will not allow SCC to hire an outside contractor to do backfilling, grading, topsoiling or equipment maintenance. This does not preclude SCC from contracting additional equipment, supervisors or permitters, however the labor force must be represented by the UMWA. SCC has expanded the search radius to locate and hire operators and mechanics to augment the workforce. SCC has also employed 2 additional contractors to address the permitting backlog. Since the October 7`" meeting, SCC has brought in two (2) additional scrapers and one (1) dozer and has increased the workforce by five (5) people. This has improved the current staffing situation to some degree. SCC will also continue to have a dedicated Reclamation Manager to communicate and coordinate planning and implementation of permitting and reclamation requirements. SCC will continue working on additional equipment staffing along with keeping the added equipment on site until the reclamation is current. Future staffing and equipment will remain at levels adequate to permit, mine and reclaim concurrently. The Division's review of a potential pattern of violations at the Yoast mine involves enforcement actions taken over a 12-month period from July 2003 through June 2004. Additional circumstances pertaining to the cause of the enforcement actions and SCC's abatement actions are discussed below. • CV-2003-006 (July 11, 2003) SCC believes that rapid snowmelt, in the spring of 2003, resulted in the considerable erosion (rills and gullies) in the recently topsoiled areas. The runoff to the south caused severe erosion in a natural channel in undisturbed/un- permitted area above Pond 011. The erosion deposited a large amount of sediment in Pond 011 resulting in less than allowable water holding capacity. CV-2003-006 was issued (July 21, 2003) and the abatement date established for October 20, 2003 and the steps to abate included: