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... -3- monitoring sets above the production panels selected for monitoring ought be extremely difficult during winter periods. The subsidence survey report format proposed within Exhibit 11 of the application is .acceptable. However, the applicant proposes a report submittal frequency of once per year, rather than the regulatory requirement of semi-annual submissions. This report must be submitted semi-annually. In fact, several operators have proposed data collection frequencies far higher than the regulatory requirements, in order to accomplish specific observations of subsidence response versus titre, etc. es 2.06,7 and 4.22: Concurrent Surface and Underground Mining and Variances from Contemporaneous Reclamation Requirements The applicant correctly observes that a variance from contemporaneous reclamation of~the final pit at the Energy No. 1 mine was granted previously, as a portion of Permit No. 79-177. An increase in the variance area is requested by the applicant, in order to permit development of the Foidel Creek underground mine's portals and the associated surface facilities. In addition, the applicant intends to modify the existing highwalZ and spoils configurations within the pit, in order to increase their slope stability. Indication of this intent tuns conveyed to the staff of the Division during previous meetings with company personnel. In order to justify the increase in variance area, the applicant should submit appropriate stability analyses and design engineering information, to demonstrate conformance with the requirements of Rule 4.22.3(1)(d) and (e), The applicant has previously indicated to the Division that such design information and engineering analyses were being completed. Further, in response to the requirements of Rule 2.06.7(3)(9) and Rule ~.22,3(I)(g), the applicant must submit a sufficient stability analysis and geotechnical investigation to aZ1ow the Division to judge the conformance of the proposed 1 million cuhic yard spoil storage pile with the performance standards and design requirements of Rule 9.09.