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IV. OSM'S Position on AOC Compliance Also Overreaches its Oversight Role and Its Own Directive on Evaluating the "General Configuration" and "Drainage" Elements of AOC Compliance. In Section B, OSM argues that no authority requires it to defer to the DMG's judgment on whether Kerr violated the AOC standazd. Once again, OSM ignores its oversight role and the appropriate standazd for judging the DMG's AOC permitting decision in OSM Directive INE-26. Exh. G-l2. Kerr explained that this Directive established that the issue for OSM is not whether it disagrees with the DMG, but whether the DMG's AOC permitting decision "was reasonable and not an abuse of discretion." Exh. G-l2 at 3; Kerr's Proposed Decision at 17-18. OSM disregarded the limits on its role, and instead took enforcement action overriding the DMG as if OSM was the regulatory authority. OSM also argues that AOC requires replicating the pre-mining ridge in Pit I, OSM's Proposed Decision at 11-12, without regazd for its own Directive. Kerr analyzed the evidence in relation to the criteria of INE-26 and demonstrated that the present configuration of Pit 1 complies with the AOC criteria in that Directive. Ken's Opening Brief at 16-22. Particulazly, Kerr showed that the general terrain is "compazable" to the pre-mining terrain adjacent to Pit 1, and in the immediate and surrounding azeas, and will support the post-mining land use. Kerr also showed that there is positive, unobstructed drainage through the Pit 1 area. ~., at 18-22. OSM rejects the relevance of these factors because of its narrow view that the ridge must be restored as it was. Indeed, OSM does not even acknowledge that Directive 1NE-26 has any relevance to its oversight evaluation of AOC compliance in this case. Two recent decisions by Administrative Law Judges Torbett and Rampton highlight the error in OSM's narrow view. Consolidation Coal Co. v. OSM, Docket No. CH 94-6-R ~o3eaf, iavv. 9