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grading or seeding. PR-3 exhibits appear to depict grading and seeding in <br />the immediate vicinity of the small substation behind the shop(warehouse; it <br />would appear that some further grading/seeding of the narrow bench feature <br />extending for approximately 100 feet to the southeast of the substation may <br />also be warranted. Finally, please address the potential for rockfall or other <br />hazards associated with the steep rock face behind the proposed migrant <br />worker housing, and whether any measures are warranted to ensure public <br />safety associated with the proposed alternative use. <br />Our rule section specific evaluation of the Steep Slope AOC variance request is <br />set forth below. <br />4.27.4(1) ...the highwall shall be completely bacl~lled with spoil material, in a <br />manner which results in a static factor of safety of at least 1.3 using standard <br />geotechnical analyses. Affirmative. <br />4.27.4(2) The watershed control of the area shall be improved... Affirmative. <br />the required demonstration was provided. <br />4.27.4(3) Land above the highwall may be disturbed only to the extent that the <br />Board or the Division deems appropriate and approves as necessary to... (a) <br />Blend the solid highwall and the backf~lled material; (b) Control surface runoff... <br />Affirmative. <br />4.27.4(4) The landowner of the permit area has requested, in writing, as part of <br />the permit application under 2.06.5 that the variance be granted. Affirmative. <br />Appropriate letter from SCC official (owner of land to which the variance would <br />be applied) was included as page A14-5-31. <br />4.27.4(5) The operations are conducted in full compliance with a permit issued <br />with 2.06.5. Pending resolution of remaining adequacy issues. <br />4.27.4(6) Only the amount of spoil as is necessary to achieve the postmining land <br />use, ensure the stability of the spoil retained on the bench, and meet all other <br />requirements of the Act and these Rules shall be placed off the mine bench. All <br />spoil not retained in the bench shall be placed in accordance with 4.09, 4.14.1, <br />and 4.14.2. Affirmative. <br />