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A formal request for a variance from approximate <br /> original contour (AOC) based on steep slope mining conditions <br /> has been submitted . Also , see Jim Pendleton ' s June 18 , 1981 <br /> letter addressing the haul road and portal situation, and <br /> the letter from the Forest Service (Appendix V-C-1) desig- <br /> nating the haul road complex as Forest Development Road No . <br /> 15307 . <br /> If you study the history of Coal Basin you find that <br /> construction of a wagon haul road to our present No . 5 mine <br /> started in the 1890 ' s and a railroad was constructed in <br /> 1900 . The present operations started in 1956 and with <br /> proven reserves will go to 2020 . Many portions of the road <br /> cuts and fills will have from 60 to 130 years of revegeta- <br /> tion either by Mother Nature or man (intensified reclamation <br /> program since 1977 ) . <br /> We believe that almost all areas , roads , pads , etc . <br /> will be either completely or partially revegetated by the <br /> closing of the mine to the extent that any attempt to return <br /> to AOC would cause great environmental harm after such long <br /> years of becoming stabilized and revegetated . <br /> It is not known if all road cuts will stabilize from <br /> now to the final reclamation but as changes will occur after <br /> the tunnel completion and time will demonstrate if any <br /> problem areas exist . It is felt that at the end of mining <br /> any or all areas will then be stabilized . <br /> If the MLRB staff feels that any problem areas exist at <br /> this time we would invite the appropriate personnel to <br /> inspect the road system . We would like to point out that we <br /> believe this to be somewhat premature as a more appropriate <br /> time , we feel , would be at the end of the tunnel construction <br /> when a "Hands on" reclamation of the road system would <br /> begin . <br /> As per our discussion in the meeting of May 26th with <br /> Jim Pendleton and Jim Herron an actual plan of the size <br /> reduction of the Class I haul roads will wait until the <br /> completion of the tunnel to Nos . 1 and 2 mines . <br /> A request for a variance from AOC was submitted on <br /> August 3 , 1981 based on the following beneficial effects : <br /> if all 175 acres of road and 230 acres of pads or work areas <br /> were returned to AOC an extreme environmental impact would <br /> occur on the watershed of Coal Canyon . The first mine <br /> opened in 1956 with 4 subsequent mines opening in the following <br /> 18 years . All of these roads and pad areas have been revegetating <br /> themselves and for the last 10 years a planned revegetation <br /> program has been in effect . The projected life of the mine <br /> is an additional 30 to 40 years . With a grand total of from <br /> 40 to 60 years of revegetation efforts on the disturbed <br /> areas it is a simple conclusion to imagine the impact of <br /> removing all of this revegetation and returning all of the <br /> ground to AOC . The impact on the watershed would be devastating . <br /> 22 . 1 <br />