2014-05-19_REVISION - C1996083 (2)

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William A. Bear Page 7 of 9 May 19, 2014 32. The list of monitoring locations on revised page 2.05 -131 no longer includes Culverts C -1 through C -4. Please provide an explanation for the removal of Culverts C -1 through C -4 from the monitoring plan or restore the text. Rule 2.05.6(6) Subsidence Survey, Subsidence Monitoring, and Subsidence Control Plan 33. Map 27 shows a structure located along the West Fork of Terror Creek at the intersection of the main entryways between Panels B -23, B -24, B -25, and B -26. There does not appear to be mention of that structure on revised page 2.05 -142, which lists all of the structures and renewable resource lands within the permit boundary and adjacent area. Please provide a description, on page 2.05 -142, of the structure located along the West Fork of Terry Creek, at the intersection of Panels 8 -23, 8 -24, 8 -25, and 8 -26. Also, the symbol for the structure is not included in the legend for the map. Please revise the legend to include the symbol used for structures. 34. Revised page 2.05 -171 indicates that the Pitkin Mesa Pipeline monuments will be installed 6 months prior to mining, but the table on revised page 2.05 -178 says that monitoring will begin one year prior to mining. Please revise pages 2.05 -171 and 2.05 -178 for consistency on the timeframe for monitoring along the Pitkin Mesa Pipeline to commence. 35. Revised page 2.05 -164 predicts a maximum subsidence of about 5.7' in the vicinity of the West Fork of Terror Creek, and asserts that this would result in no more than a 1.5% channel slope change. BRL contends that this slope change would not result in any adverse impacts to aquatic life, but does not discuss the potential impacts to water rights. a. Please expand the discussion to include any potential impacts to water users, as required by Rules 2.05.6(3)(a)(ii) and 2.05.6(b)(1)(C). b. In addition to the proposed water monitoring points (SW -01 and SW -12) and the proposed fish, sediment and macroin vertebrate sampling, please provide a monitoring plan for the West Fork of Terror Creek, in accordance with Rule 2.05.6(6)((b)(ii), to verify the accuracy of the prediction that subsidence will not result in material damage or diminution of reasonably foreseeable use of structures or renewable resource lands. Specifically, the plan should address: i. Monitoring locations along the panels to verify the maximum subsidence prediction. ii. Monitoring locations along the creek to verify the predicted change in the slope of the channel.