_GENERAL DOCUMENTS - C1981017 (280)

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Perhaps we are judging the rough rugged terrain as a poor example for considering AOC. We feel that even the present mine pads vary little from the original and surrounding terrain. Vol . 7 , Chap. V, (Add explanation and variance request as Page 23 . 1) . 9. Comment The applicant also proposes to narrow the haul roads following the completion of the rock tunnel. "The reduction (of cut slopes) will be accomplished by moving the inside ditch out into the road and allowing the cut to slough behind the new ditch. " (Page V-E-22) The permanent program regulations require backfilled areas conform to approximate original contour and achieve a minimum static safety factor of 1. 3 . In all cases highwalls must be eliminated. (Rule 4 . 14 . 2 (1) ) . Variations from approximate original contour can be considered only in accordance with the requirements of Rule 2 . 06 . 5 in "steep slope mining areas. " Rule 2. 06 . 5 (2) details the specific conditions under which a limited steep slope mining variance from approximate original ontour can be granted, as well as the performance standards which must be met in such cases. Coal Basin permit application documents do not satisfy the criteria I� of Rule 4 .27 . 4. The application should be amended to specifically address the applicant' s desire to obtain a variance for steep slope mining conditions from backfilling to approximate original contour. The applicant's presentation should include a clear and concise statement of proposed backfilling and grading configuration. This description should include appropriate maps and cross-sections of areas such as portals, roads , sediment ponds, etc. Appropriate detailed stability analyses should be included in order to demonstrate that the required static safety factors of 1. 3 will be achieved by the proposed variance backfill configurations , but not by backfilling to approximate original contour in such situations. Reply See page 82 , Sec . II-C, Chap. 2 , Vol . 1 U. S . Forest Service use of roads. Also, replies for items 5 and 8 and Exhibits V-E-1, V-E-2 and VI-D-1. Request for variance from AOC has been submitted. Also, see Jim Pendleton' s letter of June 181 1981 .