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Permit Revision Adequacy Comment Response <br />November 30, 2004 <br />Page IS of24 <br />MCC Response: MCC added the Longwall Panel numbers. <br />83. On page Z.OS-126, under "Preventative Measures," MCC will notify the Division if plans are <br />implemented of the type described which may effect the magnitude of subsidence. <br />MCC Response: Added to the "Reduction Measures" section of text. <br />84. MCC has determined that "structures" refer to buildings (page 2.05-93). The Division has a <br />long-established precedence of "structures" being defined as anything that isman-made. This <br />would include buildings, cabins, sheds, barns, stock ponds, roads, power lines, water lines, gas <br />or oil lines, water wells, vent fans, towers, swimming pools, tanks, reservoirs, etc. Map 67, <br />Man Made Structures in the Coal Lease Area, shows very little in terms of information of <br />value, especially for South of the Divide. Please submit a detailed map at an appropriate scale <br />of all structures in the current and proposed permit area. (Rule 2.05.6(6)(a)(ii)(B)) <br />MCC Response: MCC conducted a baseline natural resources survey which includes <br />stock ponds and conducted the baseline surveys for the Lower Cow Camp. The man- <br />made structures were included in Exhibit 32B and roads on Map 67 of the Permit <br />Document. The reason that the map shows very little in terms of structures is because <br />much of what the Division is suggesting does not exist in the South of Divide area. <br />Hopefully, with the addition of aerial photographs of the South of Divide area in Exhibit <br />32B, the Division can see that there are no powerlines, waterlines, gas or oil lines, towers, <br />swimming pools, or tanks in the area. <br />85. The applicant is apparently proposing to remove currently approved permit text dealing with <br />subsidence of the Apache Rocks and Box Canyon azeas. They do comment that subsidence in <br />the Apache Rocks and Box Canyon areas is addressed in Exhibit 60, which will be retained as <br />part of the approved permit. While to some degree, Exhibit 60 does contain a detailed <br />subsidence analysis done by Richard Dunrud, the DMG does not believe that the content of <br />Exhibit 60 meets the requirements of each of the rules of Rule 2.05.6(6). This is even more <br />important considering that active mining is occurring in Box Canyon right now and will be for <br />the next several years. Please retain the subsidence text from the Apache Rocks and Box <br />Canyon areas so that important information is not lost. <br />MCC Response: MCC will retain the information in the text and has included Exhibits <br />60B and 60D in this permit application. <br />86. The applicant does commendable job of presenting information in the order requested by the <br />Rules. However, given the multiple mining azeas, multiple coal seams, and the numerous <br />potential consequences to the various structures and renewable resource lands, it is somewhat <br />difficult to determine whether all subsidence consequences, mitigation, and monitoring is <br />adequate and meets the requirements of the Rules. The DMG respectfully suggests that some <br />type of summary and/or table be included under the subsidence section that clearly describes <br />each type of structure or renewable resource, the worst possible consequence of subsidence for <br />each, the subsidence control or mitigation proposed, and the monitoring necessary for each. <br />