1993-09-20_GENERAL DOCUMENTS - C1981017 (2)

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RECLAMATION SCHEDULING In the conduct of reclamation operations,one of the guiding principles is to do it once and do it right. Reclamation projects are scheduled and conducted to prevent being"painted into a corner". DMG has consistently disregarded these principles in the reclamation of Coal Basin. Road reclamation was undertaken prior to completion of reclamation activities at Mines 3 and 5, requiring redisturbance and revegetation. RECLAMATION PERSONNEL DMG has a program responsible for conducting reclamation activities, the Inactive Mine Program. This program has conducted reclamation activities at mine sites since the early 1980's. When DMG took over reclamation activities at Coal Basin, no personnel from this program were assigned to direct the reclamation. Instead, Mr. Steven Renner, a former administrator, with no construction experience was assigned to the project. By doing so, DMG has caused reclamation costs at Coal Basin to be much higher than they would have been, had an experienced construction manager been assigned the project. LANDOIVVNER CONCERNS A portion of the Coal Basin site remains in private landholdings. DMG is required to accommodate the desires of the landholders with regard to reclamation as the reclamation affects use of the land after mining. In the past, DMG has accommodated landoNvners through allowing retention of structures (buildings, roads, wells, ponds, power lines), seed mixes and plantings (forage for livestock,absence of woody plants),and other measures. In spite of landowner concerns voiced over road access, retention of structures, and sediment control, DMG has ignored these concerns. FEASIBILITY OF RECLAMATION MEASURES In completing the reclamation at Coal Basin,DMG was obligated to follow the approved reclamation plan. As illustrated above,they chose not to do so. If revision of the plan was appropriate as DMG claims,then an evaluation of the measures and testing employed during prior reclamation attempts would be prudent and appropriate to identify the measures that were tried and found infeasible or cost prohibitive. DMG ignored all prior studies and evidence, as documented with two examples below. MCR committed to study the feasibility of reclaiming slopes at Coal Basin and develop measures for reclamation based on the results of the studies. In fulfillment of this commitment, MCR initiated a revegetation test plot program on the slopes of three mines (91, 94, and #5), to evaluate whether revegetation could be successfully established on the steep slopes,at the high elevations, and on the poor"soil". This program was reviewed and approved by DMG. Quantitative evaluation of these revegetation test plots occurred in 1987, 1989, and 1991, with the evaluation scheduled to continue until 1995. The reports were submitted to DMG and showed the continued decline of vegetation on the plots. The total number of species and number of important species declined consistently, attributed largely to the steep slopes and soil creep resulting from the slope angle and harsh environmental conditions. In short,the revegetation measures would not work at Coal Basin on steep slopes. The permit documentation consistently states that any steep slope vegetation work is to be 3