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XV. Subsidence Control The applicant has predicted that no material damage will result from subsidence, therefore a subsidence control plan is not required. d. The applicant has proposed a subsidence monitoring program, in accordance with Rule 2.05.6(6)(c), designed to determine the commencement and magnitude of subsidence movements. Map 23a depicts the location of monuments to be installed and structures to be monitored within the permit and adjacent area. The results of the monitoring program will be submitted to the Division semi-annually. Exhibit 34 of the permit outlines the requirements for the subsidence report. XVI. Concurrent Surface and Underground Mining The Division proposes to grant a variance from contemporaneous reclamation for portions of the permit area in order that underground mining can be developed. This variance applies to the Area 2 pit and associated spoil from the CYCC Mine No. 1, Mine No. 2, and Eckman Park operation. Currently this area ie occupied by the portals as well as other facilities necessary to the Foidel Creek operation. TCC will be responsible for the reclamation of this area when underground mining operations have ceased (4.22.2). The Division finds that the requirements o£ Rule 4.22.3 have been met. XVII. Operations on Alluvial Valley Floors The Division has determined that an alluvial valley floor exists within the affected or adjacent area. Therefore, the following findings are in order for the alluvial valley floors known as the Fish Creek AVF, Upper Middle Creek AVF, Foidel Creek AVF, Foidel/Middle Creek AVF, and the Trout Creek AVF. Alluvial Valley Floor Identification Information pertinent to alluvial valley floor (AVF) determinations is provided on pages 2.06-1 through 2.06-17j-4, Map No. 5 (Surface Geology), Map No. 15 (Alluvial Valley Floors, Land Use and Water Rights), and the supplemental report of September 22, 1986, "Material Damage Standard for Irrigation". Map No. 6 (Twentymile Park Hydrology) from Colorado Yampa Coal Company (CYCC) Permit C-81-071 is incorporated by reference. Potentially affected portions of Foidel Creek, Middle Creek, Fish Creek and Lower Trout Creek stream valleys have previously been evaluated with respect to AVF criteria in a number of coal permits, including Twentymile Coal Company's Foidel Creek Mine (C-82-056) and Fish Creek Tipple (C-81-036) and Colorado Yampa Coal Company's Eckman Park, Mine No. 1, and Mine No. 2 (C-81-071) and Mine No. 3 (C-84-062). To summarize the previous AVF findings made by the Division; Fish Creek alluvial deposits within and below the proposed permit area, an alluvial body in Sections 21, 22 and 28 (TSN, R86W) on Foidel Creek below the proposed permit area, alluvial deposits in the vicinity of the Foidel Creek/Middle Creek confluence downstream to Trout Creek, and alluvial deposits on Trout Creek downstream to the Yampa River were determined to be alluvial valley floors. Fish Creek was determined to be an AVF based on existing and potential flood irrigation and subirrigation capabilities and findings were made 18