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Memo - Anthony Waldron - 2 - April 5, 1991 <br />they will need to amend their subsidence protection plan in accordance with <br />Rule 2.05.6(6). <br />For example, their subsidence monitoring data suggests that minimal subsidence <br />would be expected in response to limited development extraction. However, as <br />much as 8.757' of subsidence has already been observed in response to E-seam <br />longwall retreat extraction. Obviously, 8.8' of subsidence will have some <br />potentially significant implications for Highway 13. That highway serves as a <br />major thoroughfare for the public, including regional emergency services and <br />general transportation and commerce within northwestern Colorado. Items such <br />as ANFO, conventional explosives and fuel are transported on Highway 13 to the <br />Colowyo Mine, south of the Eagle No. 6 Mine. We have the responsibility of <br />determining and assuring that anticipated subsidence will not create a hazard <br />to the public health and safety. In this instance, we will ultimately require <br />a release from the Highway Department, before we can approve retreat longwall <br />mining beneath Hi 9h way 13. The Eagle No. 6 Mine, as I mentioned above, as <br />done a commendable job of monitoring subsidence during the past decade. They <br />have a better data base than most mines would with which to prepare the <br />necessary subsidence plan for approval. However, the proposed subsidence of <br />Highway 13 is going to present significant regulatory challenges, <br />nonetheless. I also suspect that additional monitoring and alarm facilities <br />will be required to safeguard the public using Highway 13's right-of-way. <br />Candidly, I believe that the Eagle No. 6 mine may have the best likelihood of <br />all the coal mines in Colorado of obtaining approval of such a plan. However, <br />I believe that obtaining that approval will require significant additional <br />subsidence protection plan submittals and significant time to process. I <br />suggest that they begin the task as soon as possible. I also believe it would <br />be extremely helpful if the operator were to arrange a preliminary meeting for <br />all the involved parties, including the Division, the OSMRE, the mining <br />company and the Highway Department to discuss this obviously important issue. <br />/ern <br />cc: Steve Renner <br />Mike Savage <br />Doc. No: 4658E <br />