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Mr. Robert F. T. ICrassa -3- Maroh 24, 1994 <br />aquifer was identified below the coal in the geology description. <br />From discussions with Basin 12esourees regarding mine water inflow, it is our <br />understanding that significant inflows of water entering the mine from below the <br />active workings occurs south of the 1'urgatoire River only. Basin ltesourrxs has not <br />scen any similar inflows into the mine from beneath the workings in the area north of <br />the river. <br />Basin believes the inflow into the mine's workings south of the river is from a fault <br />or frecture wne, rather than a sttatigraphic unit. They do not know whether the . <br />inflow is from the Trinidad Sandstone. We have asked Basin to better demonstrate <br />whether the Trinidad Sandstone in the Rancho Escondido area will be affected by <br />mining north of the river. <br />6. We cannot drift provisions to any permit in the anticipation of proposed Federal <br />regulations. Permits issued by the Division are required to be in compliance with <br />only those State statutes and regulations existing at the time of the proposed decision. <br />Should any Federal regulations be developed in the future affecting coal mine <br />reclamation, be assured the Division will promulgate similar State rules, and regtrire- <br />operators to comply with them. <br />We would like to address two points from the January 1994 document prepared by <br />Carlton Gerity entitled "Report Concerning the 13ffects of Underground Coal Mining <br />ogthe Rancho Escondido Estates". This was included in the February 22, 19941etter <br />as Exhibit 35. - _ - - <br />The fast point is with regard to the comments in the conclusion on page 2 regarding <br />the Rancho Escondido subdivision, In this conclusion, it is stated that meetings were <br />held between representatives of the Division and Raton West in December 1993 and <br />January 1994. It is further stated that "as a result of these meetings, the Iivision has <br />agreed to classify the liancho Escondido as renewable resource lands ..." <br />'ibis is incorrect. The Division does not believe the Rancho Escondido subdivision <br />should be classified as a renewable resource land. <br />The second point is with regard to the diagram on page 5. This diagram indicates <br />that the "Angle of Draw" is that angle measured between the outside edge of the <br />"cone" of subsidence and the top of the coal seam. <br />This is also incorrect. Using the pale 5 diagram, the correcx definition of "angle of <br />drew" is that angle betwcen an imagmary vertical line drawn from the outside edge of <br />a panel to the surface and the outside edge of the "cone" of subsidence. This is a <br />