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r~ <br />L <br />10. The a lication should rovi <br />monitorin an above a <br />nort west o t e aci ides ai <br />the Division with a subsi <br />aina es, s eci ica to <br />an in t e area to a mine <br />0 <br />movement, the location of movement ana the amount of intiow wh1Cn <br />is t en eo ete by movement into t e racturina. <br />Response: Peerless does not currently plan to extract pillars in <br />any areas where overburden thickness is less than 300 feet. <br />Although overburden thickness varies over the entire Coal Gulch <br />property, areas where overburden thickness is less than 300 feet <br />are primarily associated with the channels of ephemeral drainages <br />in the area to b: mined. <br />Based upon the proposed mining plan, maintenance of pillars in <br />the zone directly beneath these areas of limited overburden <br />thickness and haulage protection pillars will provide adequate <br />protection to prevent subsidence in the ephemeral drainages. <br />During the initial phases of the mining operations, Peerless will <br />conduct subsidence monitoring surveys to evaluate the location <br />and extent of any subsidence which may occur. Subsidence surveys <br />will occur on a semi-annual basis following completion of coal <br />extraction in a given monitoring zone. <br />• Peerless believes that mine related subsidence will be <br />negligible. If monitoring information supports this contention, <br />Peerless plans to work with the Division to develop a technical <br />revision allowing either partial or complete pillar extraction in <br />areas of limited overburden thickness. It is anticipated that <br />this technical revision would incorporate an expansion of the <br />proposed subsidence monitoring network in the areas of the <br />ephemeral drainages. <br /> <br />uj~, l~ Q ~'~t' <br /> <br />