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Candace Thompson <br /> June 30, 1986 <br /> Page three <br /> These disturbed area figures are correct as of May, 1986 and <br /> will be used in calculating estimated backfilling and grading and <br /> revegetation costs. <br /> The second area that needs clarification is whether or not <br /> disturbed areas in Coal Basin need to be backfilled and graded to <br /> attain approximate original contour (AOC) restoration. Mid- <br /> Continent is convinced that accomplishing a backfilling and <br /> grading program to attain AOC in Coal Basin is both impractical <br /> and wrong for the following reasons : <br /> 1. A variance from AOC should be granted in accordance <br /> with paragraph 2. 06. 5 of the MLRD Rules and Regulations on Coal <br /> Mining based on the steep slope mining conditions that exist in <br /> Coal Basin. This request was formally made by letter dated <br /> August 3, 1981 (attached as Enclosure #1) but was not approved <br /> until a geotechnical investigation and backfilling material <br /> stability analysis for the haul road and portal areas was accom- <br /> plished. The mine benches and haul roads were mapped by Geo- <br /> Hydro Consulting, Inc. , test areas were designed and constructed, <br /> and they are now being monitored. A final report of the tests is <br /> to be submitted by December 31, 1987. It appears obvious to us <br /> that complete backfilling of mine bench and haul road cuts in the <br /> extremely steep and rugged terrain of Coal Basin with the types <br /> and amounts of backfilling materials that are available is both <br /> impractical and unnecessary. Probably no other mining complex in <br /> the United States can better qualify for a permit incorporating <br /> variances from AOC restoration requirements for steep slope <br /> mining than Coal Basin. <br /> 2. Both the surface owners/managers of the land surface in <br /> Coal Basin believe that restoration of the disturbed areas to AOC <br /> is unwarranted and undesirable. Mid-Continent owns all the <br /> privately owned land in Coal Basin (approximately 5, 000 acres) . <br /> The remainder of the land surface is government land managed by <br /> the White River National Forest. The Forest Service desires that <br /> the haul roads be retained, in reduced widths, as Forest Service <br /> Management Roads. See letters from both the District Ranger and <br /> Forest Supervisor on this subject at Enclosure 2. Also, the <br /> benefits of retaining flat surfaces such as mine benches and <br /> roadways to retard the rate of flow from spring thaws and summer <br /> precipitation events, as well as providing physical habitat <br /> beneficial for wildlife species is recognized by both the surface <br /> owners/managers of the Basin. See summary of the range and <br /> wildlife history of Coal Basin prepared by Mr. Marc Bosch, <br /> District Wildlife Biologist (Enclosure 3) . In this summary, Mr. <br /> Bosch states "Termination of mining operations can have two <br /> general positive impacts on wildlife. Abandoned portals, roads , <br /> and staging areas can be put into primary production, and provide <br />