1986-11-28_GENERAL DOCUMENTS - C1981017

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Candace Thompson June 30, 1986 Page four the physical habitat useful to many wildlife species. This would be a very small, but significant, increase in available habitat. " Mid-Continent believes that any relative level areas in the otherwise steep and rugged terrain of Coal Basin would improve wildlife habitat as well as the conditions for another major postmining land use, cattle grazing. 3. With the completion of the rock tunnel and no further requirement to haul coal over the present 14 . 75 miles of haul roads, Mid-Continent plans to reduce their width from 50 '-60 ' to 30 '-40 ' from the tunnel face-up area to the mine portals. The reduction will be accomplished by moving the inside ditch out into the road and allowing the cut to slough behind the new ditch. See pages 22 and 23 of Chapter V, Reclamation, in the permit application which has been approved by both MLRD and OSM. The roads and mine portals will be retained in support of such mining activities as mine ventilation, methane gas drainage, equipment maintenance and alternate entry and escapeways. With the limited use of the roads and mine benches over the next 35 or more years of the mining operations, the cuts and fills associated with them will become settled and revegetated. It would be foolhardy to then remove the previously settled and revegetated land and create fresh disturbance that would take years to reclaim. This situation for underground mining operations has been recog- nized in a Judge Flannery decision dated May 16, 1980 (see Enclo- sure #4) . In referring to the strict AOC requirement of the SMCRA to underground mining this decision states in part, "In this situation, it is duplicitous to require the removal of previously settled and revegetated land only to achieve the purpose of a second revegetation. The court therefore remands these regulations. It directs the Secretary to provide some flexibility for settled fills that have become stabilized and revegetated. " In summary, Mid-Continent' s position on the AOC restoration requirement, as it pertains to estimating reclamation costs, is that it should not apply to Coal Basin. Reclamation costs for the mine portal areas will be based upon the reclamation plan as outlined in Chapter V of the permit application (pages 19-22) . The portals will be sealed, structures removed, concrete founda- tions broken up and together with other loose materials on the pads used as fill at the base of the portal face, non-revegetated areas will be smooth graded, available topsoil replaced and the area revegetated. The haul roads will be retained at reduced widths as Forest Service management roads and as access roads between the several portions of privately owned land in the Basin. Should mining operations cease before the haul roads have been reduced in width and stabilization and revegetation of the new configurations established, reclamation costs for those