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to Exhibit 18 of Volume 3A from Rule 2.05.6(6)(f) to Rule 2.05.6(6)(c). <br />16. The subsidence monitoring program is described beginning on revised page 2.05-115 in Section <br />2.05.6(6)(1)(v)(B). However, not all of the subsidence monitoring is required by the Division. A <br />portion of the subsidence monitoring is required by the Division but a portion apparently is required <br />by the USDA-Forest Service. Some portions may have been required through both agencies and some <br />portions may be just for BRL's information. In order to avoid any confusion, please include in the <br />subsidence monitoring descriptions beginning on revised page 2.05-115 which subsidence data is <br />required by which entity. <br />The Division has no further concerns. The various subsidence monitoring programs were described on <br />revised pages 2.05-115, 1 l6, 117 and 118 of the December 28, 2006 submittal. <br />17. The Division requests that a summary of subsidence monitoring stations be included in the permit <br />application, as has been developed for water monitoring, identifying purpose, stations, locations, <br />monitoring frequency, and better-defined start and end dates for some activities, and reporting <br />requirements. For example, when (in terms ofspatial and time relationships) will monitoring take <br />place for lines 24 through 27 (see page 2.05-115)? Monitoring is to take place quarterly (page 2.05- <br />116) for some items, but not others (photographs every 5 years). <br />The Division has no further concerns. The subsidence monitoring program summary was included on <br />page 2.05-122 of the December 28, 2006 submittal. <br />18. Please revise Section 2.05.6(6) (/) (v) (B) of the permit application to include an appropriate study that <br />verifies the angle of draw. <br />The Division has no further concerns. A report demonstrating the angle of draw was provided in the <br />December 28, 2006 submittal for inclusion in Tab 21 of Volume IIIA. <br />19. Because of the importance of the Bruce Park Dam and Terror Creek Reservoir, the Division requests <br />that, in addition to the request in the above comment for the confirmation of the angle of draw, a <br />separate confirmation of the angle ofdraw close to the dam be provided in Section 2.05.6(6)(f)(v)(B) <br />ofthe permit text. This would also provide compliance, in part, with item number 3 of Stipulation No. <br />9. <br />Referring to revised Map 14-B, subsidence monuments might be located along the centerline of Panel <br />B-12 in the location ofdepths of overburden similar to the reach between the closest mining of Panel <br />13 to the Bruce Park Dam and Terror Creek Reservoir. The line might consist often monuments, 100 <br />feet apart. The purpose is to validate the predicted angle ofdraw in an area ofsimilar lithology and <br />depths. A similar line of monuments from the point of closest long-wall mining to the dam would <br />monitor actual effects ofsubsidence towards the structure. <br />The Panel B-12 monitoring should start before the angle ofdraw reaches the 1' (closest) monument. <br />To validate the angle of draw, the frequency of monitoring should be increased. The spatial <br />relationship between the longwall face and subsidence ahead needs to be captured in concurrent and <br />5