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•. <br />During the tour, costs of reclamation ware discussed. <br />Trapper spends about $4 million per year on reclamation efforts. <br />This translates to about $2 per ton of coal produced. In <br />addition, Trapper must pay a 35 cent per ton abandoned mine <br />reclamation fee. Trapper must also pay 19.9$ federal royalties <br />on this $2.35 per ton cost for a real cost of approximately $2.70 <br />per ton reclamation cost. <br />We observed the following mining/reclamation procedures: <br />- Topsoil being stockpiled for future reclamation. <br />- Areas with direct placement of top soil. <br />- Mining of overburden in operation. <br />- Areas where top soil had been replaced <br />on re-contoured land. <br />- Areas that had been disked, fertilized and <br />seeded. <br />- Areas with grassland and seedlings growth. <br />We observed the different types of grasses and seedlings in <br />the reclamation areas. It was clear that the wildlife ate the <br />woody plant seedlings down to stubs or completely off. The coal <br />mine representatives explained the need to balance between fast <br />growing grasses for erosion control and the required "1000 stom- <br />per-acre" woody plant seedling requirements. Local officials <br />questioned whether every single acre really needs "1000 stems- <br />per-acre". It appeared that there was plenty of contouring and <br />nearby brush cover to provide adequate security for game animals. <br />We .observed a series of check dams/livestock ponds that have <br />been constructed. Reconstructed drainages were lined with <br />synthetic fabric and tack to assist in plant germination and <br />erosion control. Extensive rock check dams were also in use. <br />The livestock pond serve as water tanks for wildlife and <br />livestock and help to reduce runoff. Extensive contour ditches <br />are utilized to channel runoff into the check dams and livestock <br />ponds. Trapper has experienced a 24-fold reduction in sediment <br />utilizing this erosion control system in addition to its required <br />catch basins. <br />Trapper has received awards for "innovation" in its <br />reclamation efforts for this erosion control system. Trapper <br />officials are frustrated by retroactive OSM regulations or <br />rulings that appear to apply extensive and prohibitive <br />requirements for these livestock watering ponds. OSM rulings may <br />require that these ponds be re-engineered, reconstructed with <br />overdesigned spillways or removed. This would be inconsistent <br />with previous awards by OSM for the very system that has <br />significantly reduced sediment runoff. At the least it may <br />prevent the construction of future ponds. Currently Trapper has <br />120 of these ponds with more planned in the future. The OSM <br />rulings would also require unnecessary quarterly inspections of <br />these ponds. <br />9 <br />