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interest in using the relatively flat top of the RSRDA refuse disposal area for storage, and possible interest in future use of the light use road that extends up the draw above the refuse area (currently terminates at the reclaimed soil borrow area). As we discussed, it would appear that retention of certain buildings on the lower level and associated modification of the plan to allow for commercial use of the lower area would be relatively straight-forward from a regulatory perspective. This is because these changes could likely be accomplished without significant alteration of the currently approved final reclamation land forms and drainage configuration. Modification of the plan to allow for commercial use of the upper bench is more complicated from a regulatory perspective, due to the fact that retention of a portion of the bench would entail a variance from the approximate original contour (AOC) requirements of the rules. It is also likely that retention of a portion of the bench would significantly alter the approved final drainage designs. Also, any modification of approved final reclamation designs for the access road and upper bench would have to address reclamation of hlghwalls associated with the main South Mine portals and also the sealed fan portal adjacent to the access road. A variance from the AOC requirements of 4.14.1(2)(a) and 4.14.2(1) can be granted for underground mining operations only if demonstrations required by 4.14. i (2)(ey, br 4:14.1(2)(f), or 4.14.1(2)(8), or [2.06.5 and 4.27.4] can be made. All hlghwalls must be eliminated, pursuant to 4:14.1(2)(a) and 4.14.2(1)(b), unless a variance is approved in accordance with 4.14,1(2)(f) or (g). As we discussed, specific areas for which AOC or highwall elimination variances are requested will need to be very clearly described and delineated on appropriate maps and diagrams. The extent of hlghwalls and face-up areas will also need to be clearly delineated even if the highwall will be eliminated, in order to avoid potential future conflict regarding whether certain cut slopes in the vicinity of the mine bench and access road are or are not hlghwalls. The regulatory basis and rationale employed in delineating the extent of any highwall will need to be clearly described. At the meeting, i tried to identify same of the potentially difficult or controversial rule provisions that would need to be addressed. The following is a more extensive list of rules pertinent to the contemplated land use change, although it may not ba completely. comprehensive: 2.05,4(2)(a) reclamation plan timetable. Separate timetables should be provided for implementation of the current reclamation plan and the alternative land use reclamation plan. 2.05.4(2)(c) backfilling and grading plan. Comprehensive plans including maps and cross- sections depicting final slopes, channel designs, and road configurations will be required for the alternative land use reclamation plan. Structural demolition and proper disposal (or burial) of demolition debris will also be required, as will a plan for clean up and proper disposal (or burial} of surficial coal residue. 2.05.4(2}(d) topsoiltng plan. A plan for redistribution, seedbed preparation, and stabilization of topsoil or growth medium will be required in the alternative land use reclamation plan. If the commercial use is to be implemented within a very short time-span (e.g. less than one year) following completion of final grading, active use areas such as storage yards, parking areas, etc. may not require soil placement, preparation and vegetative stabilization, However these considerations would apptyif there wilt be a delay in implementation of the alternative land use, and would also apply to areas not designated for active use, but which