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State Rule 2.05.6(6)(c), quoted below, provides detailed <br />requirements for a subsidence monitoring plan: <br />(c) Subsidence Monitoring Program. <br />(i) The monitoring program shall be designed to <br />determine the commencement and magnitude of subsidence <br />movements which occur and shall include the following <br />monitoring techniques: <br />(A) Monuments shall be installed and surveyed prior to <br />the commencement of mining. <br />(B) Monuments shall be situated to appropriately <br />monitor ground surface movement, vertical and <br />horizontal, within the proposed permit and adjacent <br />area to accommodate the predicted angle-of-draw. <br />(C) The orientation, location, and elevation of each <br />structure within the permit and adjacent area shall be <br />monitored. <br />(D) Monitoring of established monuments and structures <br />shall be performed at least quarterly, commencing one <br />month prior to the initiation of mining beneath any <br />established monument or structure. <br />(E) Results of the monitoring program shall be <br />submitted to the Division at least semi-annually. <br />(F) The monitoring program shall be designed to extend <br />for a time, beyond cessation of mining in any area, <br />consistent with the need for verification of the <br />subsidence prediction. <br />To summarize, in its response to the TDN, DMG asserted that, <br />under its regulations, Basin was not required to submit a <br />subsidence survey or subsidence control plan for the portion of <br />the mine under the Tatum property because subsidence was not <br />predicted to occur under the Tatum property. DMG further stated, <br />however, that Basin was required to submit a subsidence <br />24 <br />