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Richard Mills <br />Page 3 <br />March 13, 1998 <br />Fish Creek and it's alluvial valley floor are the most significant environmental feature yet to be <br />proposed for subsidence by operations a[ the Foidel Creek urine. Water quality, quantity, historic <br />practices, and land-use mapping all indicate signifrcant AVF areas are proximate to areas of <br />potetrtial impact <br />As TCC is aware, the Division approved subsiding a small portion of Fish Creek dare to nritti»g in <br />Panels 5 and 6 ojwhat TCC now apparently refers to as the 6Vestern Mir:itrg District. Extensive <br />monitoring conducted indicated that impacts were measurable but did not appear to be lasting. <br />Based on discussion and analysis of this limited subsidence of an AVF, the Division approved <br />subsiding Foidel Creek in the EMD. This more extensive subsidence of a perennial stream would <br />provide valuable information [o investigate, and determine whether or no[ a perennial stream can <br />be subsided for a significant distance without long-term impacts. <br />TCC must demonstrate to the Division, via the permitting process, that Fish Creek can be <br />subsided without lasting long-term impacts. It is not the responsibility ojthe Division to search <br />through prior reports and data, incorporated by generic reference, and come to some conclusion <br />which favors subsiding Fish Creek for /7, 500 feet. TCC is required by the Rules to present <br />information to support the planned activities in a logical and detailed format. The Division will <br />review this specific information, in conjunction with all other available information, and attempt <br />to verb that the requirements of each and every Rule have been met. Presently, this cannot be <br />done with the information provided. <br />22. Please indicate that 7R longwall panel will also undermine and subside County Road No. 33 <br />during either the current permit term or the next permit term. Also, indicate the 5 year permit <br />terms specifically (i.e. 1993-1998 or 1998-2003), rather than stating "this permit term" or "the <br />next 5-year permit term". <br />32. Surveying on the pool areas does verify the accuracy of the prediction of the number of acres <br />where farming will be precluded due to subsidence. However, it does not verify or monitor for <br />potential changes to the remainder of the alluvial valley floor of Fish Creek. Please review the <br />original question as shown below. <br />TCC states on page 2.06-17(j)(6) that additional survey work will be conducted. The Division <br />can only assume TCC plans on submitting additional information to satisfy the requirements of <br />Rule 2.06.8. !n par[icu/nr, the Division calls attemion to Rule 2.06.8(4) and will expect that TCC <br />wit! submit information to adequately address each individual section of this Rtrle. Rule <br />2.06.8(4)(x) requires the application include detailed surveys and baseline data and that it be <br />complete, concise and accurate. hrcorporating past hydrologic, geomorphic, and subsidence data <br />generically by reference is not acceptable. While this data is etrtirely valid for use to assist irr <br />characterising the ,4 VF, it needs to be presented in the cortex! ojthe subsidence ojFislr Creek. <br />Cross-sections and Wraps of [he AVF should be srrffcient in rr:rmber to charncteri.e the entire <br />portion ojthe AVF to be affected as well as the portions below wlricir rely on Fish Creek waters. <br />Please review Rule 2.06.8(4)(c). One notable omission at this time is a plan for environmental <br />monitoring required by 2.06.8(-1)(u)(vi) to meus'rrre compliance rvi[h the performance standards of <br />Rule-1.24. Afeasurement of alluvial water level and quality at various locations along the stream <br />will be critical Cross-sections, periodically surveyed, xil! also be necessary. A program, si»rilnr <br />