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<br />Subsidence Monitoring Program <br />The applicant references the existing surface subsidence monuments on <br />page 2.05.6(6)-15, and depicts their location on Map tlo. 31, entitled <br />"Subsidence tonitoring". The new application does not contain any <br />details of monument construction. The applicant should include the <br />description and drawings contained within the original application <br />documents. These should be utilized to supplement or replace the <br />subsidence monuments in the future. <br />The application discusses the initiation and conduct of subsidence <br />monitoring, on page 2.05.6(6)-16. The text states; "additional <br />monitoring points will be installed at least one (1) month prior to <br />initiation of possible mining-induced subsidence based on the projected <br />19° angle of draw. Monitoring of monuments shall be performed at least <br />quarterly, commencing one (1) month prior to initiation of mining <br />beneath any established monument or structure." It is desirable to <br />survey a monument or structure at least twice prior t:o the initiation <br />of subsidence, in order to ascertain whether the monuments are stable <br />and properly installed. This ensures reliable monuments and avoids <br />loss of data. The applicant should amend their text appropriately. <br />The applicant proposes no monitoring plan in relation to the AMOCO Oil <br />Pipeline or County Road 107. It is probable that some monitoring <br />program will be required for these structures, which will be impacted <br />during the initial five year mine permit. <br />4. The applicant proposes no monitoring <br />13, the Railroad Spur, or the Yampa <br />associated alluvial valley floors. <br />programs will be required for these <br />lands, which will be impacted during <br />Subsidence Survey <br />plan in relation to State Highway <br />and Williams Forts: rivers and their <br />It is probable that monitoring <br />structures and rernewable resource <br />the life-of-mine. <br />The subsidence survey contained within the application is concise and <br />thorough. In my opinion, the applicant should be commended for this component <br />of the application document. <br />Subsidence Control Plan <br />The application briefly addresses subsidence control for the AMOCO oil <br />pipeline, on page 2.05.6(6)-45. The applicant proposes to undermine <br />the pipeline during the initial five year permit period. As referenced <br />above, I believe the applicant's treatment of this potentially <br />environmentally sensitive structure is far too brief,. The original <br />permit for the Eagle mine complex provided a subsidence controi plan to <br />protect the pipeline from the potentially damaging consequences of <br />surface subsidence. The pipeline was protected through the maintenance <br />of a buffer zone of limited extraction within the Ho.. 5 mine room and <br />pillar workings. Before this sensitive structure can be subsided, the <br />applicant will have to demonstrate that either the pipeline can resist <br />the strains resulting from the proposed life-of-mine activity, or that <br />