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~~~u,vccl to (r'Sk a.ll ~~~; -:: ,.a,~ ~~ Page 2, Mr. David A. Bent' / ~! C [ ye% '~ I `~ k V~r~ ~-'~¢ c~!.; ^ ; The correct definidon of a ewcture under the regulations is unclear, Even the definition of "structure" in the 015a of Surface Mining's proposed subsidence riles, which is very broad, limits the definition to "buildings, wnetructed objects and improvemerts." Pipes lying on the ground and uninhabitable buildings have rat been wnsidered to be swctures. The t+enmants of previous use of an area should not be regulated as structures, as we do not believe it wes the intent of the rule to protcet valueless ertitticts of prior activity ffom subsidence effects. 4. Attached is a copy of Federal Coal Lease C-0117192 and a consent agreement signed with ,~,{ ,, .,`the Previous landowner. Also attached is a wpy of an agreement with Mr, Mautz to access his ' property to the west. 5. The descriptions provided in question No. 5 of the Division's Jarwary 13, 1994, letter are believed to be current and accurate. , 6. The years of F-seam mining provided in question No. 6 of the Division's January 13,1994, letter are correct. More apecificaUy, development mining in that area approximately occurred during June 1989, and retreat mining during August 1990, 7. A portion of Mountain Coal Compares most recent B-seam mine plan is attached and shows the mined and plarmed mining areas in the B-seam. 8. Jumbo Spring No. 3 pond wee designated ea spring No. 12 in the Woodward-Clyde Consultenta hydrologic investigation report wmpleted in the late 1970'e and was designated es spring CR-12 in the B-seam technical revisioa (No. 55). Springs CR-12 and G-26a are in the same vicinity, but are not believed to be the same resource. 9. Yes, MCC began monitoring the subject spring in September, 1993, and now refere to it as G-26B. 10, No, spring G-26B wee not located during the Woodward-Clyde Consultants hydrologic investigation and was not included in the original Lone Pine Gulch monitoring program (which was discontinued in 1986, due to landslide activities). 11. MCC wntinues to believe that neither the spring nor the "pipeline" has been injured by mining in this area. MCC has mined under the subject spring and the overall subsidence (or lowering) was approximately 2.25 feet (sea Exhibit 60, Volume 12, for the calculated F-seam subsidence). Of greater import, the area has and continues to slide, As stated previously, the majority of Lone Pine Gulch has been mapped as "Qls" or landslide debris. Dames and Moore, "Landslide Investigation Report", September 1993, wncludea that "the North Fork of the Gunnison River vellry has a long history of slope instability" and "the fact that sliding is still occurring is evidenced by fresh cracks , tumgeteted scarps, and toppled vegetation associated with recem movement.... Theso observations suggest that the area has had a long and probably continuous history of elope movements, .,. Subsidence may bs secompanied by surface craekutg.