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Variability in roof conditions means not every coal mine is able to support the roof in a way that will prevent roof falls from killing the miners with the minimum roof support. The clause "Additional measures may be required in plans by the District Manager" (30CFR § 75.222)" addresses these shortcomings to suit the requirements of the individual mine's roof control plan to best protect the miners, without having to hold the entire industry to an unreasonably high standard, just to protect the miners at the mine with the worst conditions. By having the discretion to individually allocate minimum support at each mine based on the conditions present, this clause is actually saving the rest of the industry from having to follow stricter regulations everywhere.

Executive Order 12866 requires agencies to tailor regulations to impose the least burden on society. Having individualized roof control plans does this by imposing the burden of following stricter guidelines on only one mine instead of requiring every mine in the country to follow those stricter regulations

Removing this clause places the onus of miner safety more fully in the operator's hands to be able to address conditions that are not addressed in the minimum roof control requirements set forth by the regulations. The District Manager adds individualized mine requirements based on the conditions of each mine to ensure the safety of the miners working there. These additions are non-arbitrary and based on addressing the conditions of the mine. If this ability of the District Manager is removed, more miners will die from roof falls where the minimum roof control requirements are not sufficient to address individual mine conditions.

2016 marked the first year in US history where 0 roof fall fatalities occurred. Having additional requirements for each mine at the discretion of the District Manager is proven to work at preventing roof fall fatalities.

In addition, preventing fatalities by using appropriate roof support to begin with simply costs less than addressing fatalities. The annual savings estimated by this proposal of $1.1 million over 10 years is outweighed by the cost of addressing fatalities that will occur if mine-specific regulations, addressed by the District Manager, are removed.

The rule change also cites that this role change will result in "a more efficient Agency review and approval of roof control plans for underground coal mines." If every proposed change to a roof control plan needs full comment periods and the equivalent status of a publicly-applied law for a change that should only affect a single mine, the roof control plan approval process will significantly slowed.