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9 - <br /> change of use of structures or renewable resource lands. <br /> . Therefore it is determined that subsidence that has occurred <br /> has not resulted in material damage to or diminuation of <br /> reasonably foreseeable use of structures or renewable <br /> resource lands. <br /> 6. Subsidence monitoring program. A subsidence monitoring <br /> program was initiated by MCR in 1981 . Subsequent surveys <br /> were carried out in 1982 , 1983 , 1984 and 1985 in accordance <br /> with this plan (Vol . 7 , Chapter IV, pages 33-37) and subse- <br /> quent revisions. The results of this program are summarized <br /> below. MCR contends that sufficient data have been collected <br /> to characterize subsidence and subsidence-related phenomena <br /> in the Coal Basin area, i.e. that the subsidence ratio of <br /> measured disturbance to coal thickness removed is approxi- <br /> mately 0. 30, substantially less than the ratio of 0.55 as <br /> predicted in the permit; that the angle of draw averages <br /> approximately 18° as opposed to the CMLRD stipulated value <br /> of 20. 59 and that there are no visually observable effects of <br /> subsidence, such as surface cracks, hummocked profiles (sub- <br /> sidence pits) , or subsidence-induced slumps or landslides. <br /> There has been no observable damage to structures or other <br /> man-made facilities such as roads or power lines over mined- <br /> out areas, in spite of nearly 30 years of mining activities, <br /> including 8 years of longwall mining, which results in <br /> essentially total extraction of the full thickness of the <br /> • coal bed involved over wide areas, or to renewable resource <br /> lands or aquifer recharge areas. There are no significant <br /> variations in the. general geology of the area that would <br /> indicate that subsidence or subsidence-related phenomena will <br /> differ in the future from what has been observed to date. <br /> There is likewise no evidence, based on data accumulated to <br /> date, that any damage due to subsidence or subsidence-related <br /> phenomena will occur to structures, renewable resource lands <br /> or. aquifer recharge areas in the future. <br /> Because of the extremely rugged topography and severe climate <br /> of the Coal Basin area, which limit dependable access to sub- <br /> sidence monitoring and control points to between July and <br /> September and in addition require helicopter-supported sur- <br /> veying, the subsidence monitoring program is very costly. <br /> Since data accumulated to date indicate that both the subsid- <br /> ence ratio and the angle of draw are less than the worst <br /> case predictions contained in the permit application, because <br /> no visual effects of subsidence have been observed in spite <br /> of the 30-year period during which mining activities have been <br /> carried out in Coal Basin, and because there is no evidence <br /> of damage to or diminuation of structures, renewable resource <br /> lands or acquife.r recharge areas, or to foreseeable use of <br /> structures or renewable resource lands , MCR requests suspension <br /> of the subsidence monitoring program. <br /> l� <br />