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INTRODUCTION <br /> Rule 4.03. 1 of the Colorado Mined Land Reclamation <br /> Division 's Rules and Regulations for Coal Mining addresses_ <br /> specific criteria for the design and construction of haul <br /> roads. Since the haul roads in Coal Basin were constructed <br /> many years prior to passage of the Surface Mining Control <br /> and Reclamation Act of 1977, there were no design standards <br /> for construction of these roads. Rule 4.03. 1 (e) allows for <br /> alternative design criteria and specifications to be used if <br /> it can be shown that "such alternatives will be as environ- <br /> mentally sound and structurally stable as that resulting <br /> from haul roads complying with the requirements of 4.03. 1 <br /> and meet such other criteria as are necessary to acheive <br /> reclamation in accordance with the requirement of this rule, <br /> taking into consideration physical , climatological and other <br /> characteristics of the site" [emphasis addedl. <br /> The purpose of this certification is to determine if <br /> the Coal Basin Haul Roads meet the criteria of Rule <br /> 4.03. 1 (e) . I hereby state that I am a professional engineer <br /> in the State of Colorado and have been involved in the <br /> construction and reclamation of mine haul roads for seven <br /> years. In addition, I have been in charge of maintaining the <br /> Coal Basin road/drainage system for the last two years and <br /> have made many personal observations concerning the <br /> stability of this road. <br /> BACKGROUND <br /> Mid-Continent Resources, Inc. has been actively <br /> involved in underground mining operations in Coal Basin <br /> since 1956. Approximately 15 miles of haul roads were <br /> constructed from the lower preparation plant (altitude <br /> 8000 ' ) to the mine portals (altitude 10,000'+) (Figure 1) . <br /> The topography of the Basin consists of a broad valley <br /> surrounded by a very steep sloped ridge. The ridge is made <br /> up of Mesa Verde shales and sandstones while the valley is <br /> composed mainly of Mancos Shale and colluvial outwash from <br /> the Mesa Verde formation. Avalanches and rock slides are <br /> very common occurrences in Coal Basin. Heavy winter snows <br /> (150+ inches annually) combined with intense summer <br /> thunderstorms are causing the topography of the Basin to be <br /> in a continual state of change. <br /> The road systems connecting the mine portals and the <br /> preparation plant were constructed many years prior to the <br /> enactment of the Surface Mining Control and Reclamation Act <br /> of 1977. Accordingly, design of the roads was dictated by <br /> considerations other than the design standards of the <br /> Federal Act. The haul roads were constructed taking into <br /> account the following criteria: <br /> - surface topography of the surrounding area. <br />