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We have heard from a number of States that there were wide variances in how the criteria for inclusion in the inventory were presented. What exactly were the criteria and were Field Office Directors given detailed uniform guidelines for determining whether a project was appropriate for inclusion in the inventory? Was any field verification performed? Could you provide documentation for the record of field verification?

The criteria used for the inventory update were contained in
the August 1984 "AML Inventory Update Manual". This
information was provided to the field offices and States in
1984 prior to beginning any update of the inventory. The
criteria contained in this manual have provided the basis for
the content and format of material submitted by the States and
the review completed by the Field Offices. Field verification
was performed on all submissions with estimated reclamation
costs greater than $500,000 and a sample of all others.
Documentation exists at each Field Office on the verification.
Due to the volume of this material, we have attached an example
of a problem area in Ohio (OH-1043). This example is typical
of those found in other Field offices, and contains the
original submission, problem area data form (PAD), and
documentation of field office verification. Since this
material is voluminous, it is not included for the record.

Question: What procedures specifically were used in updating the inventory?

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The specific procedures used in the update of the inventory are contained in the attached 1984 Inventory Update Manual.

How were these procedures communicated to the field offices?

This manual was distributed to field offices immediately upon publication. The distribution of the manual marked the initiation of the inventory update process and occurred with an instruction course provided by AML staff and consultants.

Does the lack of uniform procedures explain the fact that West Virginia's inventory is 62 percent highwalls whereas only seven percent of Ohio's inventory is made up of highwalls? Dangerous highwalls are an AML problem associated with surface mining throughout the country. In addition to West Virginia, several other States have identified a large number of dangerous highwalls, either alone or in connection with other AML problems. For example, approximately 80 percent of the Oklahoma inventory, 46 percent in Pennsylvania and 43 percent in Arkansas contain dangerous highwall problems.

Was there any linkage made between a State's intent to actually
perform a project and that project's conclusion in the
inventory?

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Sites contained in the inventory include all priority 1 and 2 problems (and associated priority 3 problems) identified by the States or Tribes. The inventory has been designed to provide a description of all known high priority sites. There has never been a restriction that only sites for which reclamation was planned could be submitted.

Did OSM provide any guidance to the States concerning reclamation techniques or were the States allowed to choose whatever reclamation technique they wanted for purposes of padding their inventory?

In 1981 OSMRE undertook an extensive effort to examine,
document, and disseminate the latest information on AML
reclamation techniques. This information was compiled in an
AML reclamation technology handbook and contained chapters on
subsidence control, mine fire control, mine drainage control,
coal waste stabilization, spoil instability control, support
facility reclamation, and mine land reclamation. Once provided
this information, States were allowed to choose techniques
contained in the handbook or any other technique they could
support as being effective.

Inventory submissions were reviewed by the technical staff at
the OSMRE field offices to determine that the reclamation
method was reasonable and costs were within the guidelines.
If the reclamation method was unusual or not typically used
under conditions described in the submission, additional
justification was required for approval.

According to a memorandum from the Chairman of the National Committee which reviewed the updates to the inventory the Committee did not question whether a specific reclamation technique was the best or correct reclamation method. Why was that?

Technical evaluation of submissions was completed at OSMRE Field Offices. This evaluation consisted of review of descriptive material followed by an on-site review of all submissions over $500,000 and a sample of all others. Evaluation of the reclamation method was one of the specific elements of this stage of the review. The National Committee did not undertake a technical review of the submissions, but rather it reviewed submissions for consistent application of the prescribed criteria.

A document entitled Comments on Missouri AML Inventory Updates
Reviewed Feb. 18-20, 1986, which was prepared by the National
Committee goes so far as to recommend a more costly means of
reclamation for a dangerous highwall. Reading from the
document: "Guardrails are an acceptable and economical means
of 'reclaiming' the problem and will probably be used in this
PA (problem area). However, Missouri might consider
reclaiming this DH by backfilling through a resubmittal to

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obtain maximum credit for this problem." Why would the National Committee want to recommend a method that they admit will not likely be used but is more expensive and will pad the State's inventory?

The committee comment regarding Missouri PAD # MO-0056 states
that the State might consider backfilling rather than
guardrails as the reclamation method. In this case it appears
that the committee was saying that guardrails abate the problem
but backfilling is the common form of reclamation that
eliminates this problem. A copy of PAD #MO-0056 is attached.
Given the obvious problems with the inventory have you given
any thought to alternatives for allocating the discretionary
share? When the inventory approach was chosen what other
alternatives were considered?

OSMRE has asked the States for recommendations on leaving the inventory open for one more year and for an alternative approach to allocating AML funds. OSMRE will meet with the States to discuss options which may be available for a new allocation formula, including possibly dropping the inventory as an allocation factor.

Other alternatives considered for allocating the discretionary share included geographic location (return more than 50 percent of funds to the States where they were collected), historic production only, and inventory only.

For the record could you provide an analysis of the impact of distributing the discretionary share based on 50 percent historic coal production and 50 percent current coal production?

The attached table shows this distribution by State for the FY 1988 discretionary funding.

I understand that the Interior Committee has recommended the elimination of 68 positions in OSM's Headquarters and Eastern and Western Field Offices. Do you support these proposed cutbacks and what would the impact be of these reductions?

The Department does not support the cutbacks proposed by the Interior Committee. They would seriously affect OSMRE's ability to accomplish its mission at a time when it has almost completed augmenting its field organization to accommodate those functions which were decentralized in 1986-87. If OSMRE were required to absorb the cuts proposed by the Interior Committee for FY 1989, a major reorganization in both Headquarters and the field would be inevitable.

Over the last two years, the percentage of total positions in the field has increased from 59% to 65%. Reducing staff by this amount would necessitate an immediate hiring freeze, thus eliminating all current vacancies.

Inspection staff includes supervisors and administrative support personel.

There is presently is no coal mining in Mississippi.

*** The West Virginia program did not specify the inspection program staffing level. The above numbers reflect the regulatory

program staffing level which also includes permitting and other.

Interagency Agreement

between

The Office of Surface Mining Reclamation and Enforcement

U.S. Department of the Interior

and

The National Park Service

U.S. Department of the Interior

"Reclamation of public health, safety, and general welfare problems within the New River Gorge National River, Big South Fork National Recreation Area and Friendship Hill National Historic Site that have been caused by past mining practices."