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REV104078
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Entry Properties
Last modified
8/25/2016 1:15:10 AM
Creation date
11/22/2007 1:13:32 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
Revision
Doc Date
2/24/2005
Doc Name
2nd Adequacy Letter
From
DMG
To
Mountain Coal Company, LLC
Type & Sequence
PR10
Media Type
D
Archive
No
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Page 8 of 20 <br />84. Original Comment: MCC has determined that "structures" refer to buildings (page 2.05-93). <br />The Division has along-established precedence of "structures" being defined as anything that <br />is man-made. This would include buildings, cabins, sheds, barns, stockponds, roads, power <br />lines, water lines, gas or oil Zines, water wells, vent fans, towers, swimming pools, tanks, <br />reservoirs, etc. Map 67, Man Made Structures in the Coal Lease Area, shows very little in <br />terms of information of value, especially for South of the Divide. Please submit a detailed map <br />at an appropriate scale of all structures in the current and proposed permit area. (Rule <br />2.0 5.6 (6) (a) (i i) (B)) <br />MCC Response: MCC conducted a baseline natural resources survey which includes <br />stock ponds and conducted the baseline surveys for the Lower Cow Camp. The manmade <br />structures were included in Exhibit 32B and roads on Map 67 of the Permit Document. <br />The reason that the map shows very little in terms of structures is because much of what <br />the Division is suggesting does not exist in the South of Divide area. Hopefully, with the <br />addition of aerial photographs of the South of Divide area in Exhibit 32B, the Division can <br />see that there are no powerlines, waterlines, gas or oil lines, towers, swimming pools, or <br />tanks in the area. <br />New Comment: MCC responded that "structures were included in Exhibit 32B and roads on Map 67 <br />of the Permit Document. " Map 67 shows Minnesota Reservoir as the only structure in the SOD azea. <br />Drawings lA and 1B of Exhibit 32B show stock ponds (which qualify as structures) and other <br />renewable resource lands. Neither of these drawings meet the certification criteria of Rule 2.10.3(2). <br />A cabin and Cow Camp are referred to but do not appeaz to be included on the map. <br />The permit application document should cleazly identify each structure (man-made feature), provide a <br />brief description, and be shown on a map that meets the standards of Rule 2.10. The original DMG <br />comment stands. <br />85. Response accepted. <br />86. Original Comment: The applicant does commendable job of presenting information in the <br />order requested by the Rules. However, given the multiple mining areas, multiple coal seams, <br />and the numerous potential consequences to the various structures and renewable resource <br />lands, it is somewhat difficult to determine whether all subsidence consequences, mitigation, <br />and monitoring is adequate and meets the requirements of the Rules. The DMG respec fully <br />suggests that some type of summary and/or table be included under the subsidence section that <br />clearly describes each type of structure or renewable resource, the worst possible consequence <br />of subsidence for each, the subsidence control or mitigation proposed, and the monitoring <br />necessary for each. DMG is willing to discuss any other ideas MCC has to bring this important <br />information into focus. <br />MCC Response: MCC has included a natural resource survey with inventory. <br />New Comment: The original question stands. MCC's response refers to a natural resources survey. <br />The DMG response is that a summary discussion and table should be provided to cleazly describe each <br />
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