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RESPONSE TO JUNE 7, 1994 <br />ID OF INTERESTS LETTER <br />1. Page A-1 has been clarified to show that the officers and <br />directors listed are for Grand Valley Coal Company. It should <br />be noted that the position of Vice President is now vacant. <br />2. Crand Valley Coal Company has been notified that White Oak <br />Mining and Construction is owned by Donald Todd Kiscaden. Scott <br />Kiscaden is on the board of directors. GVC has no idea how OSM <br />got their information. <br />3. Figures 1.1-3 a & b have been revised. <br />4. Grand Valley Coal Company or previous owners have been mining at <br />the McClane Canyon Mine since early 1977. This mining activity <br />predates the Rule cited. Additionally, GVC leases the area to <br />be mined from the Bureau of Land Management. The BLM is <br />notified of all activity at the mines through both the <br />Division's procedures and the BLM/MMS reporting requirements. <br />These requirements include the adoption of a resource recovery <br />and protection plan required by 43 CFR 3482.1. These plans and <br />permits as well as the Logical Mining Unit Formation Application <br />are adequate to notify the BLM of the mining plans for the area. <br />It is my interpretation of Rule 4.20.2(1), (2), and (3) that the <br />surface owner should be notified that mining is to commence so <br />that the surface owner can monitor the effects of mining with <br />regard to subsidence related property damage. The Division has <br />on numerous occasions made the determination that no subsidence <br />monitoring or control is necessary because there ere no surface <br />structures or renewable resources in the effected area. <br />The Division has indicated to me that this section of the rules <br />is to be followed if mining at an operation ceases and then <br />begins again. I see no provision of the rule that supports this <br />interpretation. Taken to extremes, is the operator required to <br />give six months notice if he intends to resume mining after <br />stopping for a three day Christmas weekend ? <br />RESPONSE TO JUNE 14, 1994 <br />INSURANCE CERTIFICATE LETTER <br />A new insurance certificate is included that expressly includes <br />the use of explosives. <br />Mc Page - 1 7/12/94 <br />