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-8- <br />Subsidence - Rule 2.05.6 <br />The Preliminary Adequacy Letter requested the submission of the semi- <br />annual subsidence survey monitoring results, which the original application <br />stated were collected for 1979 and 1980. The purpose of the request <br />is to verify the applicant's statement that no significant subsidence <br />has occured on the site. The amended application contains Drawing <br />2.05.6(6)(c)ii-1. This drawing indicates the location of several <br />dozen control points and subsidence monuments within the Bear Mine permit <br />area. However, no survey data collected from these monument locations is <br />presented in the amended application to verify the applicant's original <br />statement. The applicant must supply that data in order to allow the <br />preparation of a concurring finding. <br />Adequacy Review - Bear No. 3 Permit Revision Submittal <br />This review of Bear Coal Company's permit revision for the proposed <br />Bear No. 3 mine has revealed several deficiencies and concerns which <br />must be resolved before the Division can begin making written findings <br />on various aspects of the permit revision portion of the permit <br />application. <br />Permit Application Form <br />On page 2 of the application form, I00% non-federal mineral ownership <br />has been circled. This should be revised to show IOOo federal ownership <br />of federal coal lease No. D-052501. <br />1, Financial and Compliance Information - Rule 2.03 <br />2.03.9 The Certificate of Insurance submitted by the applicant is <br />inadequate. The public liability policy must be upgraded to provide <br />minimum coverage of $300,000 for each occurrence and $500,000 aggregate <br />for bodily injury, and $300,000 for each occurrence and $500,000 <br />aggregate for property damage. This policy must remain in full force <br />during the life of the permit and must include a rider requiring that the <br />insuror notify the Division whenever substantive changes are made in the <br />policy. <br />Environmental Resource Information - Rule 2.09 <br />(Land Use Information - Rule 2.09.3) <br />The application on page 2.09-3 states that "the soils within the area <br />to be disturbed by the surface facilities of the underground mine are <br />limited in their agronomic usefulness. The applicant should describe <br />how these soils are limited in their usefulness to agriculture. Soils <br />in alluvial areas are often sufficiently developed to be useful in <br />agricultural operations. Additionally, the land capability and productivity <br />analysis on page 2.09-9 does not adequately address the premining potential <br />of the surface facilities area as agricultural land. The alluvial area <br />encompasses approxi ma rely ZS acres and may potentially be suitable for <br />some type of limited agricultural operation, such as a small hay meadow. <br /> <br />