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Recent Rockfall <br />The Division believes that the recent rockfall east of D-seam longwall panel D-9 has significance <br />for any longwall mining near rock cliffs at the Bowie No. 2 Mine. This includes the extension of <br />D-seam longwall panel WD3 that is proposed in TR-31 since it appeazs that rock cliffs maybe <br />affected by subsidence effects from this panel extension. Therefore, the Division has the <br />following questions concerning rockfalls as they relate directly or indirectly to TR-31. <br />6. Recognizing the recent rockfall on the Hubbard Creek Road just south of the junction <br />with Dove Gulch, please validate that the surface subsidence feature is within the Extent <br />of Subsidence Based on Mine Plan line, and include the rock run-out azea within the <br />Affected Area line. <br />Concerning the recent rockfall, please add to the Worst Case Damage description on page <br />43, Volume III, Exhibit 15, a description of potential rockfall damage and add rockfall to <br />the warning sign (page 44). <br />8. The Division requests that BRL provide whatever subsidence monitoring information is <br />available for the azea azound the rockfall. Referring to Map 27, this would include any <br />data from subsidence monitoring points 17-A, 17-B, 17-C, 17-D, 23-A, 23-B and 23-C. <br />9. The Division received a letter dated December 8, 2003 from the Paonia Ranger District of <br />the U.S.D.A.-Forest Service concerning the recent rockfall that was reported by BRL. Jim <br />Stover, BRL's consultant, was copied on the letter. The rock fall is on Forest Service <br />land, near the intersection of Dove Creek and Hubbard Creek. In the letter, the Forest <br />Service stated that the rockfall blocked a section of the Hubbazd Canyon road and <br />probably occurred as a result of subsidence from the Bowie No. 2 Mine. Along with the <br />Forest Service's requirement to put up warning signs now, the letter also states that BRL <br />has agreed to perform the necessary repair work, perhaps in the Spring of 2004. <br />Rule 4.20.3 requires that mitigation actions be taken to protect the surface owner from <br />any reduction in the value or use of the surface lands. The Division requests that BRL <br />submit a repair plan to the Division concerning this recent rockfall. The repair plan <br />should include a schedule of proposed actions and a tentative time schedule. If blasting is <br />to occur, please review the blasting regulations concerning possible notification and <br />record keeping requirements. <br />10. The recent rockfall is evidence that rockfalls can be expected from outcrops in steep <br />terrain as a result of subsidence. Therefore, certain requirements of Rule 2.05.6 apply. <br />A. Under Rule 2.05.6(6)((e)(i)(F)(IV), the areas subject to rockfall nmout should be <br />identified on an appropriate map and described in the permit application text, such <br />runouts being a related phenomena. <br />2 <br />