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ss LNYIRDNNLNTAL PRO?ECI70N aTANDARDa Because of the evolution of the surface coal mining industry, reclamation and environmental protection actions are often viewed as necessary evils to be tacked on to the end of a process that bas been developed for the purpose of producing coal at the ]east possible cast E=penance with sound reclamation practices, fiowever, indicates thst the best a roach to mining and reclamation involves the combining of both of these acfjvitiea m one.process. Thus there is ample evidence to reject assertions that "the reclamation sad mining processes cannot be combined." In fad, the opposite is true. The authors of one recent engineering study concerned with the design of new end more environmentally acceptable minim systems observed in reviewing current practices that " reproduction mina planning and desi~!n is not a prcrcquisite to profitable mining" and thus for the surface mining industry in the Eastern coal firlds, "the mininrrgg urethods employed in the early 1970's remain essentially uncbenged since their inception, even though equipment used has changed over the years (e.g., the front~nd loader has replaced the power shovel for stripping and coal loading):' In addition "because reclamation con- sists of aseries of distinct poshmining activities--appended, as it wen, to aerating mining methods-the potential for sigmficant further re- duction in the environment impacts of surface mining is severely limited." (:lfathematica, pa -.) A basic tenet underlying this legislation is the principle that theemi- ronmental protection and reclamation, at. a minimum meeting the standards in this act, are a coequal objective with that of producing coal. T]re continued selection of minrrr~ techniques by engineers whose primary objectives are the most elficrent removal of the overburden end transport of the coal is not sufficient to be fully responsive to the ~urpoers and intent of the act Tforeover, if the mine design ob- jectives include the environmental performance atandarrls as elements In be thoroughly integrated in the overall mining process instead of treated as separate ntusls to be performed mereh because they are required, then rt is Hite probable that accornplishment of the environ- mental practices will become cost-effective. The following is a discussion of the key environmental perfornrance standards of H.R. 2 Return to approximate miyirral contour H.R. 2 requires that the mine site be regraded to the approximate original contour. ilforeover, the regrading standard of H.R. 2 wos formulated to cover all types of mrmng operations under all condi- tions Thus it is, of ne~rty, a flexible standard which contemplates different mining cirenmstancea The bill's critScs have alletmd, to the contrary, that the term "approximate original contour" imposes en overly ngid and impractical requirement It. should lx• rmphasized, therefore, that a reasonable roterpre~ation of Ii.R. Y rannnt ludify the assertion that Ure bill requires either the imppnnssaildr latik of rrslorat.ion of the orieinal contour or fire useless act of diF~in~ a new pit to obtain fill material to achieve frill restorntion of tlrr onFrnal tolur.~rnnhy.