1987-12-01_PERMIT FILE - C1981017 (201)

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techniques for stabilizing severe erosion areas. This report and its conclusions that the haul roads could be adequately reclaimed were approved by the Division. It should be noted that interim reclamation consists of moving the tow ditch out into the road and allowing cut slopes to slough naturally. This will allow the steep sections to naturally reduce their angle. When sloughing has stabilized, the sloughed areas will be revegitated. Personal Observations - My personal observations of the haul road system during the past two years confirm the observations made by Geo-Hydro. That is, there are many areas of minor to moderate stability problems associated with the cuts and fills of the road system. The areas of severe stability are, for the most part, due to natural erosional processes. The fact that the haul roads have been in existence for many years, and that the cut areas have undergone many years of revegitation efforts, have combined to provide a greater degree of stability for this road system. Due to the topography and climate of Coal Basin, further disturbance of the roads in order to bring some sections into compliance with Rule 4.03. 1 would result in greater short-term erosion problems and more impact to the environment of the Basin. CONCLUSIONS At the time of construction the haul roads were built using state-of-the-art techniques practiced at that time. Although many of these techniques are no longer accepted, the roads do meet many of the modern design criteria dealing with alignment and grades. In order to bring the cut and fill slope grades into compliance it would require a great deal of earthwork construction and cause great disturbance to the environment of Coal Basin. The reclamation plan contained in Mid-Continent 's permit application appears to be the most environmentally sound course of action. Given the physical , climatological and other characteristics of Coal Basin, and based on the facts presented here;, I certify that the existing road system is as environmentally sound and as structurally stable as can be, given the prudent state-of-the-art techniques practiced at the time of construction. The techniques used in the construction of the haul roads fall under alternative design criteria as specified in Rule 4.03. 1 (e) .