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FEB-02-99 10 :26 AM ESCO_ASSOCIATES 303 499 4276 P. 03 <br /> NECESSITY OF STEEP SLOPE REVEGETATION AT COAL BASIN <br /> Mid Continent Coal (MCR) sought and ultimately was granted permission to <br /> mine coal under provisions of a permit issued by the Colorado Division of <br /> Minerals and Geology and its predecessor, Colorado Mined Land Reclamation <br /> Division. These provisions included the requirement to revegetate disturbed <br /> areas pursuant to Section 4.15 of Colorado regulations, themselves in <br /> conformance with requirements of Federal regulations Section 817.111. MCR <br /> sought and was granted variance from requirement of state (and federal) <br /> programs to return disturbed surfaces to approximate original contour, This <br /> variance from AOC did not include variance from the requirement to <br /> revegetate, and, by virtue of their request, MCR in some ways made the still <br /> present task of revegetation more difficult for themselves. Mining in Coal Basin <br /> inevitably involved working on steep slopes. Benches built for roads and <br /> working platforms inevitably left a cut and fill, above and below the bench <br /> respectively, with slopes steeper than the original ground surface configuration. <br /> Along with the benefit to MCR of relief from spending the money to undertake <br /> the earthwork needed to establish AOC, MCR also assumed the difficulty of <br /> dealing with revegetation of even steeper slopes than would have been present <br /> with AOC. <br /> The fact that the slopes above and below road/work benches were even <br /> steeper than the originally steep conditions in no way diminishes the practical <br /> need to have vegetational cover restored to protect them from erosion. In <br /> fact, the opposite is true. Increased steepness makes these slopes more <br /> vulnerable to erosion and the need for protective cover greater. <br /> 3 <br />