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Mr. Robert F. T. ICrassa -4- March 24, 1994 <br />significant error, in that for a depth of 750 feet from the surface to the coal seam, a <br />true 15° angle of draw would produce a surface subsidence effect 201 feet from <br />beyond the edge of the underground workings. Using an angle of 15° in the diagram <br />on page 5, the extent of surface subsidence effects from the edge of the underground <br />workings would extend 2799 feet, which in actuality corresponds to a tnie angle of <br />draw of 75°. <br />Letter dated February 25. 1994 <br />The Division is aware of the possibility of strucwres being built within <br />Rancho Escondido after the issuance of this permit. Subsidence control plans <br />developed pursuant to Rule 2.05.6(6)(b)(iii)(B) are, however, developed only after the <br />"description of worst possible consequences" required pursuant to 2.05.6(6)(b) <br />determines that subsidence could cause material damage or diminution of reasonably <br />foreseeable use of structures and renewable resourre lands (2.05.6(6)(b)(i)). )f <br />stnudures or renewable resource lands do not exist within the area of subsidence <br />effects at the time of the preparation of the description of worst possible ' <br />consequences, or, if they do, Urey would not be expected to experience material <br />damage or diminution of reasonably foreseeable use;. then. an applicant would not have <br />to prepare a subsidence control plan as. described in 2.05.6(6)(f). <br />In the case of the Golden Eagle Mine, however, Basin Resources and the Division <br />have agreed that Basin will develop a control plan for any new structure built after the <br />permit is issued if mine-related subsidence `could cause material damage or <br />S-r~ ~ diminution of reasonably foreseeable .use.of such structures`T as described -in <br />2.05.6(6)(b)(i). Basin realizes its need for compliaace with State statutes regarding <br />development of subsidence control plans, but also recognizes that these plans aren't <br />required if structures or renewable resource lands don't exist within the area to be <br />subsided. The Division believes that the comments supplied by the operator are the <br />best way to document the operator's recognition of potential future compliance issues <br />regarding mitigation of subsidence-related effects, without limiting now what the level <br />of that subsidence mitigation might be. <br />2. Please provide the ownership information you believe is incorrect. This information <br />/~1 /Z should be current to no later than January 21, 1994, the date of the Division's <br />proposed decision to renew the Golden Eagle permit. <br />3. Basin Resources has submitted a revised structure inventory and structure inventory <br />~~ P map. Please let us Imow what other materials you believe have not been submitted by <br />Basin Resources. Please also let us ]mow whether you have reviewed the newly <br />submitted information, and what issues, if any, you have regarding its adequacy. <br />4. You are correct in commenting that Basin Resources' post-mining land use map <br />M R identifies post-mining land uses solely for the disturbed areas associated with Basin's <br />