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the CDMG revisit the statute to determine if there is any flexibility available to address this specific situation in a more direct and appropriate manner. It may be that the Rule 3.03.1 bond release provisions • can be used a general procedural framework, with consideration and documentation of the mitigation and risks associated with this specific site relative to the overriding objectives of public health, safety, and protection of the environment. Specifically; • The CDMG's determination on the application should be a liability release determination, since no bond is held • Rather than using backfilling, grading, drainage, reestablishment, and revegetation as the criteria for making a liability release determination, the determination should be based on "major subsidence effects" as identified in the CMLRD Policy memorandum of April 13, 1987, with a finding that, on completion of mining, operational mining controls and any subsequent mitigation have effectively controlled or addressed potential adverse impacts to public health, and safety, and protection of the environment • The phasing approach, outlined by Rule 3.03.1, is not applicable or appropriate, and any liability release determination should represent a final determination, with no corresponding extended reclamation liability period Since similar liability release concerns exist for all Colorado underground coal mining operations, it may also be appropriate to consider rulemaking to address the issue in the long-term. 11. Several additional surface cracks mid surface holes were observed north of the air monitoring station during the November 18-19, 2004 inspection. These are Feature No. S, Feature No. 6, Feature No. 7, Feature No. 8, Feature No.9, Feature No. 10, and Feature No. 11. These surface features overlie the 1'~` West workings in T6N, R91W, Section 31. Map 23, "Eagle No. 5 F Seaur Workings", does not show tlaat pillar extraction was conducted in this area of the mine. Please provide ai explanation at to the cause of the apparent subsidence in this area overlying room and pillar workings. Does RAG-EC/BTU-Empire expect to see similar subsidence features on lands overlying other room and pillar workings where pillar extraction was not approved to occur? Response: Review of the referenced Map 23 indicates that multiple-seam mining occurred in the general area where the noted features were identified. Map 23 shows advance mining on the F-Seam, but also shows the outline of previous mining for another coal seam (the Hart Seam, mined in the Wise Hill Mine). It is unknown whether or not pillaring Cook place in the Wise Hil] Mine, however, the observed localized subsidence features are probably a reflection of the superposition of the overlying mine workings and/or natural stumping and subsidence over natural burn zones near [he coal outcrop. Similar features do not occur and are not expected to develop over areas that have not been pillared and where multiple-seam mining has not occurred. 12. Flooding of underground workings and/or fluctuations of the water level due to ongoing pumping may potentially affect the integrity of mine floor, mine roof, and the remaining pillars. RAG- EC/BTU-Empire continues to pump mine water at both the No. 5 Mine sump (CPDS outfall 003) mrd North Angle 7 Well Bore (CPDS outfall 024). What is the water level elevation in the mine workings? Please designate on a map what portions of the mine workings are flooded. How long have these portions of the mine workings been flooded? If areas of the mine being requested for release are still being dewatered, then please designate these areas on the map. Please also indicate the anticipated flooded water level in the release areas when pumping ceases Liability Release Response - No. 3 5 12/07/05