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PREFACE FOR SUBSIDENCE MITIGATION PLAN The Subsidence Mitigation Flan has been completed as required by Special Condi- tion 3 of the Office of Surface Mining-Mine Plan Approval, The mitigation plan was developed for Colorado Westmoreland Inc. by Centuries Research of Montrose, Colorado. Centuries Research has done most of the archaeology studies around the Orchard Valley Mine and was selected because of their prior work and exper- tise in this area, The mitiyation plan states specific recommendations on page 14, The recommenda- tions will be addressed and specific commitments made by CWI in Chis preface, Centuries Research recommended that the Step I effort be initiated as soon as possible, CWI believes that it would be best to delay Step I work for a few years, CWI believes that the work needs to he done but can be delayed for the following reasons: 1. Because of the large amount of overburden in the vicinity of Site 5DT700, CWI believes subsidence will cause minimal effects. This is based on recent subsidence monitoring information. The report is correct in stating that no previous research work has been done on the actual effects of subsidence on a similar site. CWI believes that with current subsidence monitoring, the minimal effects projection will be Confirmed, 2. Site 5DT700 is located on the permit area boundary. Based on the subsidence information that can be gathered within the next few years, the angle of draw may be such that the site will not be affected by underground mining. As was stated in comment dl above, this information will be confirmed within the next few years. See attached map for location of Site 5DT700 relative to projected mining. 3. After consultation with Centuries Research, CWI believes that Step II should be completed very soon after Step I confirmed mitigation necessity. This approach would make certain that once attention is drawn to this area the archaeology work would be completed quickly and potential vandalism would not be possible. CWI would want this Step II mitigation program to be ini- tiated very close to undermining of the area if it was determined that sub- sidence would affect the site. 4, Undermining of the area around SDT70U would not take place for the next sev- eral years. CWI has completed a 5-Year Mine Plan schedule that would not call for mining in this area for approximately 7 years. This projection would be true only if the mining rate was approximately 1 million tons per year, Currently, C.WI projects mining could be only a fraction of that amount. There is truly no reason to complete the work until undermining is confirmed for the area, ;~ -„ . ia= _/ FHB ~ ~ i~^6 ~~r ~~~~