Cumberland Reclamation Company v. Secretary, United States Department of the Interior

Paragraph 1232(a) of the Surface Mining Control Act deals with a reclamation fee for “surface coal mining” and another (lesser) fee for “underground mining.” Section 1201(c) refers to surface mining operations and “disturbance of surface areas ... by destroying or diminishing the utility of land.” Section 1202(e) discusses reclaiming of “surface areas” contemporaneously with “surface coal mining operations.” In § 1291(28), “surface coal mining operations” are defined as

activities conducted on the surface of lands in connection with a surface coal mine ... including such common methods as…