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Failure to provide a detailed operations plan of the <br />proposed (or actual) underground workings. Jim Tatum <br />property. <br />See Exhibit A for copies of the State rules. <br />3. DMG's Re~onse to the TDN <br />By letter dated December 20, 1993, DMG responded to the OSM <br />TDN (AR III-26). In its response, DMG denied that Basin had <br />violated the State coal mining rules referred to in the TDN. <br />Concerning the subsidence inventory of structures, required by <br />State Rule 2.05.6(6)(a), DMG asserted that Basin had conducted <br />such an inventory. In support of this, DMG attached to its <br />letter a portion of the permit map which depicted the Tatum <br />property. <br />With respect to alleged violations of State rule 2.05.6(6), <br />concerning Basin's alleged failure to properly conduct a <br />subsidence survey, subsidence monitoring, and subsidence control <br />plan, DMG referred OSM to State Rule 2.05.6(6)(b), asserting that <br />this provision of the State program requires an applicant to <br />submit a subsidence survey and subsidence control plan only if <br />subsidence were predicted to occur. DMG stated that, since the <br />Tatum property lies principally within the Purgatoire River <br />Alluvial Valley Floor (AVF), and since subsidence beneath an AVF <br />is strictly prohibited, Basin was prohibited from mining in a <br />manner that would allow subsidence beneath the Tatum property. <br />DMG asserted that the permit for the Golden Eagle mine contained <br />22 <br />