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Permit Revision Noll <br />Response to CDMG Adequacy Comments, March 78, 2005 <br />Page 3 <br />(d) a description of measures taken to mitigate the effects of any material damage <br />MCC's Response: MCC added text to pages 2.05-95 through 2.05-138 of the PAP <br />(attached) to address the Division's concerns. <br />6. None of the information submitted and reviewed for PR-11 indicated the presence of <br />structures or renewable resource lands in the lease area. The applicant should <br />include permit text that indicates the presence or absence of structures or renewable <br />resource lands in the West Flatiron lease tract. <br />MCC Response: The information was submitted in the EA completed by the USFS <br />and was submitted by MCC as Exhibit 40. No structures occur in the lease area and <br />none of the renewable resources (springs and Raven Creek) will be impacted or <br />undermined as stipulated as part of the lease approval. MCC has shown on Map No. <br />3 the projected angle of draw at 25 degrees. Map No. 37 shows the springs in the West <br />Flatiron Lease. On page 2.05-157, MCC addressed the issue of ephemeral and <br />perennial springs and how the springs are outside the area to be affected by <br />subsidence. <br />New Comment: The Division requests that the permit text in section 2.05 should clearly <br />state the presence or absence of renewable resource lands in the permit and adjacent area in <br />accordance with Rule 2.05.6(6)(a) for the West Flatiron Area. Please state in the permit text <br />that there area no structures. Please state in the permit text that the renewable resource lands <br />along Raven Gulch and any springs are not within the affected area. This is all that is <br />required under the subsidence section for the West Flatiron permit revision (PR-11). <br />MCC Response: MCC has addressed these permit text changes at Page 2.05-101. <br />7. If applicable, the worst possible conseguences due to subsidence (rockfall) relative <br />to any structures or renewable resource lands should be discussed in the permit text. <br />If necessary, monitoring or mitigation measures should also be specifically <br />addressed in the permit text. <br />MCC Response: There are no identified rockfall areas within the West Flatiron <br />Lease area (see Map 1 of Exhihit 60C). All of the mapped rockfall areas overlie <br />longwall panels within the previously approved Box Canyon permit area. <br />New Comment: Please state in section 2.05 of the permit text something to the effect "there <br />are no identified rockfall areas within the West Flatiron lease area, as shown on Map 1 of <br />Exhibit 60C. Therefore, any possible subsidence-induced rockfall in the West Flatiron <br />Lease area should be of insignificant consequence." <br />MCC Response: MCC added the suggested text at Page 2.05-105. <br />8. Response accepted. <br />