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XV. Subsidence Control <br /> Section 2.05.6(6) of the permit application contains information on predicted impacts <br /> from subsidence. PSC predicts no subsidence will result from the approved mining <br /> because the underground mining will be limited to room and pillar mining in which <br /> pillars will not be removed. A monitoring program designed for verifying the <br /> predictions of no subsidence and no impacts to structures or renewable resources is <br /> contained in the permit application package. <br /> XVI. Concurrent Surface and Underground Mining <br /> No variances for contemporaneous reclamation for combined surface and underground <br /> mining operations (2.06.7) is needed due to (1)the Seneca II Mine having ceased <br /> operations in 1999 and having been reclaimed and terminated; (2) the excavated pit <br /> accessing the Wadge Seam to construct mine portals and other facilities to support an <br /> underground mine not being considered surface mining; and(3)the Peabody Sage Creek <br /> Mine reclamation bond including any remaining facilities from the Seneca II Mine. <br /> The Division finds that the requirements of Rule 4.22.3 have been met. <br /> XVII. Operations on Alluvial Valley Floors <br /> The Division has determined that an alluvial valley floor exists within the affected or <br /> adjacent area. Section 2.06.8 of the permit application contains information on alluvial <br /> valley floors (AVFs). The following three AVFs are within the area of influence of the <br /> PSC: The Fish Creek AVF, the Grassy Creek AVF, and the Little Grassy Creek AVE <br /> The Fish Creek AVF extends the length of Fish Creek to its confluence with Trout <br /> Creek. The Grassy Creek AVF is a 45-acre area near the Grassy Creek/Little Grassy <br /> Creek confluence. The Little Grassy Creek AVF is a 40-acre area that extends along a <br /> narrow strip on both sides of Little Grassy Creek upstream from the Grassy <br /> Creek/Little Grassy Creek confluence. The Division previously determined that Cow <br /> Camp Creek, an ephemeral tributary of Fish Creek, is not an AVE <br /> The Division a f f i r in s its previous AVF determination for the Fish Creek AVF that is <br /> documented in the findings documents of the Foidel Creek Mine (C 1982056). Alluvial <br /> deposits on Fish Creek meet alluvial valley floor criteria based on existing flood <br /> irrigation, potential for flood irrigation and subirrigation. <br /> The Division affirms its previous AVF determinations for the Grassy and Little Grassy <br /> Creek AVFs. Prior to regulatory recognition of AVFs, the Seneca II Mine (C1980005) <br /> established the Grassy Creek and Little Grassy Creek AVFs. As allowed under Rule <br /> 2.06.8(5)(a)(1) and (ii) for operations conducted prior to August 3, 1977 within or <br /> Page 24 of 27 <br />