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Memo to Dave Berry <br />Bowie No. 2 Geotechnical Adequacy Responses <br />page 8 <br />modified predictive techniques. It has been my pleasure to know Dr Abel <br />and to participate in reviewing his subsidence predictions and analyses on <br />numerous occasions. Dr. Abel's techniques, which have been employed by <br />previous permitted operators within Colorado, are acceptable to the <br />Division. I must confess, however, that I have not become so versed with <br />these techniques that I can always recognize their application without the <br />benefit of the applicant's noting that they are being applied. Nor do I <br />believe they have necessarily achieved the status of "conventional <br />wisdom" implied by the tone of BRL's response. <br />BRL now informs the Division that the graph included within Exhibit 15 is <br />not the SEH figure, as earlier indicated, but is indeed a version modified <br />to reflect Dr. Abel's modified predictive technique. With the benefit of <br />this revelation, I concur that the predictions included in the application <br />are consistent with this methodology, which has proven to be generally <br />applicable and conservative in predicting subsidence within Colorado coal <br />fields. <br />Paragraph 2 <br />BRL's adamant opinion concerning the non-similarity of panel #36 in the <br />Bowie No. 2 Mine and the 1st West and 2nd West Panels of the Orchard <br />Valley (now Bowie No. 1) Mine is noted. <br />Paragraphs 3 and 4 <br />Once again, having been appraised of the actual modified predictive <br />techniques being used within the original preparation of Exhibit 15, I <br />concur with Dr. Abel's methodology, and are acceptable to the Division. <br />The projections which I offered in my earlier adequacy comments were <br />based on "worst case" projections, assuming totally effective recovery. <br />While I can understand BRL's reluctance to condone such a conservative <br />approach, it is normally the Division's mandated point of view. <br />Paragraph 5 <br />Subsidence monitoring, as outlined on amended page 2.05 - 92 -, applied <br />