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-` Petter O'Conner - King Coal - 2 - March 6, 1987 of the field observations submitted by the permitters' consultant indicate that, in some areas, the ditch is heavily overgrown. It is assumed that this overgrowth, where it occurs, may inhibit observation of the Ditch. Due to the highly qualitative nature of the quarterly field observations, the Division feels that the submittal of field survey data would be beneficial in determining if subsidence processes have occurred above the King Coal Mine in the vicinity of the Huntington Ditch. Depending upon the results of the field surveys, modifications to the approved plan (reduction or addition) may be proposed by the Division. During the permit renewal process, National King Coal, Inc., submitted a "Mine Plan View" map dated September 26, 1986. This map suggests that mining may occur beneath Pine Gulch in portions of mining Sections Numbers 4 East, 5 East and 6 East. This potential mining activity below Pine Gulch again raises the concern that the gulch may be adversely affected by subsidence processes. To address the Divisions concerns, the operator should respond the following: (1) Does National King Coal, Inc., plan to, or propose to, extract coal from beneath Pine Gulch? If no coal extraction is planned or proposed, "Mine Plan View", (Drawing X-002) should be revised to indicate areas of proposed coal extraction; (2) If mining will take place beneath Pine Gulch, the operator should: (a) Address the stream characteristics (ephemeral, perennial, or use for irrigation water transport). {b) Determine if the water is adjudicated; for what purposes, and in what quantities. (c) Investigate the potential magnitude of the surface expression of subsidence when it occurs in this area, given the minimal amount of overburden; (d) Based upon the expected magnitude of surface disruption, the operator should propose a quantitative subsidence monitoring program; and (e) The operator should propose mitigative measures to be undertaken, and alternative sources of water, if appropriate. To summarize, National King Coal, Inc., has obtained quantitative and qualitative subsidence data near the Huntington Ditch. Although the qualitative data has been submitted to the Division, an assessment of subsidence processes at the surface cannot be made until the field survey data is submitted to the Division. When that assessment is made, a recommendation to terminate or otherwise modify the monitoring program may be made by the Division.