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<br /> <br />It will be necessary for the Division to review the results of the <br />survey, the proposed monitoring plan, and proposed repair methodology, <br />prior to commencement of the potentially damaging undermining. For <br />this purpose the applicant will need to commit to a schedule for the <br />submission of such a survey report and monitoring and maintenance <br />repair plans. <br />(3) In our earlier adequacy comments we indicated that the three additional <br />structures inventoried as existing near the boundary of Sections 25 and <br />26 were not discernable on the maps included within the permit <br />application. The applicant responded that the structures were <br />indicated on Map #14. I have once again examined Map #14. Once again <br />I have been unable to locate the structures. The applicant should <br />amend Map N14 to clearly depict the location of all inventoried <br />structures. I recommend that we require them to add "flag or baloon <br />labels" to the map to identify the structures. <br />(4) In our earlier adequacy review, the Division stated; "All roads, <br />whether used by mine personnel, ranchers, hunters, or the general <br />public should be inventoried. It will be necessary to monitor their <br />condition and to develop a general plan for repair, if necessary." The <br />applicant has responded that the roads, with the exception of County <br />Road No. 27, are controlled by TCC. Further, the company indicates <br />that "necessary repairs (if any), will be completed during surface <br />reclamation activities." <br />As I stated in (1), above, this response is inadequate to satisfy my <br />earlier adequacy concern. The operator will have to describe the <br />methods of "controlling access" to the subject roads. The Division is <br />responsible for assuring the protection of the public, including <br />hunters, ranchers, tourists, etc. The operator must provide sufficient <br />detail to allow the Division to find that the health and safety of the <br />public is assured. I recommend that signage be installed at <br />appropriate locations on the roads, whether or not access is supposedly <br />"controlled", to inform people of the potential hazards. Further, I <br />doubt that the applicant actually intends to cavalierly wait until <br />final reclamation to restore any roadway which might be damaged by <br />subsidence. I assume that some of these roadways are necessary to <br />maintain needed access for maintenance, monitoring, and assuring that <br />access is "controlled". The applicant should provide a description of <br />the timing and methodology of subsidence damage repair to be exercised. <br />cc: Bob Liddle <br />JP/jP <br />Doc. No: 1459E <br />