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Sec tio~t 2.1.9. Subsidence The treatment of subsidence presented in this section of the application is inadequate to satisfy the requirem~~n[s of [see Federal Permanent Regulations. 30 CF[: 784.20 applies to subsidence co~itrol plans Eor underground nines. 3U CFR 817.121, 817.122, 817.124 and 817.126 further delineate performance standards for subsidence control, notification and surface owner proter_tion. 30 CFR 784.20 specifically requires that the application include a survey, which is commonly referred to as the subsidence survey. The contents of this survey may vary. Subsidence compliance is also a phased process in which the outcome of one phase either may require continuation to the next or may be sufficient to complete the process. In its first phase, this is "a survey which shall show whether structures or renewable resource lends exist within the proposed perms[ and adjacent area and", as a second phase, "whether subsidence if it occurred could cause material damage or diminution of reasonably forseeable use of such structures or renewable resource lands." The first task of this phase is straightforward but is definitely missing in the application. The applicant must inventory [he permit and adjacent area to delineate whether structures or renew:361e resource areas are present. Barring contrary evidence, the regulatory authority assumes these to be present, as the inclusive definition of "renewable resource lands" is presented in 30 CFR 701.5 as "aquifers and areas for the recharge of aquifers and oilier underground waters, areas for agricultural or silvicultural production of food and fiber, and grazinglands." (This is interpreted to include significant springs and perennial streams at a minimum). The second task is to determine if material damage or diminution of use may occur, based on an assumption that subsidence will occur. This analysis does not require a sophisticated prediction of subsidence - it strictly requires an acceptable estimate of "worst case" subsidence and its effects on structures and renewable resource areas. The Federal Regulations intentionally and specifically avoid defining material damage to allow flexihility in liability litigation; however, a reasonable view of material damage caould be loss in part or whole of personal property (real or intangible) for which the person deserves compensation to be made whole. (30 CFR 701.5 presents a definition for ""laterially damage the quantity ur quantity or quality of water"; however, in view of the Federal Preamble, (FR vol. 44, no. 50, p. 15075), to accept such definition in consideration of subsidence is not indicated). The consideration of material damage, as a suggestion, would include structures and other personal property in the area. The Land Use portion of the application (Sec. 4. 1) reports that past, existing and future use of the