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-4- <br />The proposed disposal methods will have to be carefully specified, in order to <br />assure that thelmaterial properties achieved will be consistent with the final <br />geotechnical investigation and stability analysis performed in accordance with <br />the requirements of Rules 2.05.3(6)(b)(c)(d). <br />Subsidence - Rule 2.05.6(6) <br />1. The application must include a subsidence survey, subsidence monitoring <br />and subsidence control plan, in accordance with Rule 2.05.6(6). The brief <br />treatment included on pages 123 and 124 of the application suggest that the <br />subsidence will be prevented by limiting extraction to less than 50%. <br />The brevity of the presentation renders it grossly inadequate for permitting <br />purposes. The applicant should amend the application to respond specifically <br />to Rule 2.05.6(6). It will be important for the amended application to <br />clearly depict and describe the anticipated affects of subsidence. If the <br />applicant proposes to utilize subsidence control, such as limited extraction, <br />to prevent material damage from occurring, then a submittal should be prepared <br />in accordance with the requirements of Rule 2.05.6(6)(f). In all likelihood, <br />a subsidence monitoring program, as required by rule 2.05.6(6)(c), will be <br />necessary to verify predictions included within the presentation of the <br />subsidence control plan. <br />Hydrologic Balance - Rule 2.05.6(3) <br />The applicant must submit a description of the probable hydrologic <br />consequences of mining. This description should include the impacts of mining <br />on the quantity and quality of both surface and ground water. Impacts which <br />should be assessed and described include: <br />1) depletions of flows in Harvey Gap during and after mining; <br />2) impacts of mine water on water quality in Harvey Gap during and after <br />mining; <br />3) impacts of the coal refuse pile on water quality in Harvey Gap; <br />4) impacts to the quality and quantity of ground water; and <br />5) impacts to ground water use (wells and springs). <br />The applicant should assess the significance of each potential mine impact. <br />The applicant should describe those measures it will employ to minimize <br />surface and ground water impacts to both water quality and water quantity. <br />The applicant should then provide a plan to mitigate any water quality or <br />water quantity impacts which will cause degradation of water quality or <br />diminution of water quantity off-site. <br />Alluvial Valley Floors -Rule 2.06.8 <br />1. A statement on page 55 indicates that flood irrigated alluvial deposits <br />of the Colorado River are contained within the permit area. Figure 1 <br />indicates that no irrigated lands are present within the permit area. This <br />discrepancy should be clarified. <br />