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Permit Revision No. 5 - PAR 2 <br />July 5, 1994 <br />Page 6 <br />the final target selection, the system was abandoned and the <br />permit was revised back to the original traditional surveying <br />methodology. <br />Before the Division could approve the identical revision <br />application again, MCC will first have to explain why they now <br />believe they can effect aerial photogrammetric surveying <br />within the required accuracy specifications. Following that <br />justification, MCC will have to verify the proposed <br />methodology while simultaneously continuing proven traditional <br />surveying. Once a successful verification by demonstration <br />has been completed, MCC may be approved to discontinue the <br />traditional survey methodology for subsidence monitoring. If <br />interested, MCC should prepare and submit an appropriate <br />Technical Revision application. <br />However, until that time MCC, should monitor certain <br />structures, i.e. springs, which will be undermined to <br />determine the timing, as well as magnitude, of the proposed <br />subsidence. <br />3. Since Dames and Moore is the recognized expert, it is the <br />Division's position that the recommendations of their study <br />should be followed rather than entirely disregarded. If the <br />conclusions and recommendations of the consultant are ignored <br />then the study had no purpose and should not have been <br />conducted in the first place. Also, it is possible that some <br />monitoring stations could be limited to foot access only. It <br />is not necessary that roads be bladed to within five feet of <br />every monitoring site. <br />However, if MCC wishes to pursue a program of periodic surface <br />mapping, which employs aerial photography and field <br />verification, to monitor the occurrence of sliding above the <br />area of proposed mining, then MCC should submit sufficient <br />detail describing the methodology and frequency of the <br />proposed mapping program to allow the Division to render a <br />decision regarding an enforceable landslide monitoring mapping <br />proposal. <br />4. The map, while confusing because its drawn to imply angle of <br />draw interception with a planar topography, is conservatively <br />acceptable to the Division. <br />5. The various models proposed by prominent subsidence <br />researchers and theorists all have in common the prediction of <br />various layers or zones of ground response. Each differs <br />slightly regarding the relative thickness of each layered <br />zone. Each of these models assumes a relatively infinite <br />