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real time (to determine the angle ofdraw). The Panel 13 monitoring should start before the angle of <br />draw reaches the closest monument to the long-wall mining. <br />The subsidence monuments for panels B-12 and B-13 should be shown on Map 27. <br />The Division has no further concerns. Map 27 and page 2.05-118 were revised in the December 28, <br />2006 submittal to include the two additional subsidence monument lines for panels B- 12 and B-13. <br />20. The GEI Consultants, Inc. letter ofMay 2Z 2003, Re: Additional Analysis: Geotechnical Evaluation <br />of Mine Induced Seismicity on Bruce Park Dam was originally submitted to the Division for Technical <br />Revision No. 22 but never incorporated into the permit application. The Division requests that this <br />letter be added to Volume X Geotechnical Studies Bruce Park Dam. <br />The Division has no further concerns. The submittal dated December 28, 2006 contained the requested <br />letter, which is to be placed in Tab 3 of Volume X. <br />21. Rule 2.05.6(6)(1) requires that the subsidence control plan be `prepared by appropriately qualified <br />professionals ". None of the reports in Exhibits 15, 16, 17 or 18 bear appropriate certifications. In <br />addition, the reports in Exhibits 15 and 18 do not identify who prepared the reports. Please provide <br />such information. <br />The Division has no further concerns. The December 28, 2006 submittal contains updated cover pages <br />for Exhibits 15, 16, 17 and 18. <br />22. Figure I on page 4 of the Exhibit 17 report shows a B-seam mine plan that is more extensive than the <br />mine plan proposed on revised Map 14B and Map 27 of PR-10. In order to avoid any confusion, <br />please either revise Figure I to only show the mine plan proposed in PR-10 or add a note to Figure 1 <br />that states that the B-seam mine plan approved in PR-10 is shown on Map 14-B and Map 27 of the <br />permit application. <br />The Division has no further concerns. Figure 1 in the December 28, 2006 submittal was revised to <br />contain the appropriate note. <br />23. Under Rule 2.05.6(6)(1)(iv) on revised page 2.05-114, BRL states that the operator will repair any <br />mine-related damage and be responsible for damage to injured parties as it relates to the Bruce Park <br />Reservoir. However, Rule 2.05.6(6)(1)(iv) requires a detailed description ofsuch mitigationplans, as <br />further described in subparagraphs (A), (B), (C) and (D) of that rule and in Rule 4.20.3. The Division <br />also understands that any workperformed on the Bruce Park Dam structures mustfirst be approved <br />by the USDA-Forest Service. Please revise page 2.05-114 and the subsidence handbook in Exhibit 15 <br />to describe in detail the mitigation plan for the Terror Creek Reservoir. <br />BRL deleted references to any possible damage to the Bruce Park Dam. The rationale is as mentioned <br />in comment number 4 above. The seismic and subsidence monitoring program falls under Rule <br />2.05.6(6)(c) rather than Rule 2.05.6(6)(f), since there now has been a determination that no material <br />damage will occur to the Bruce Park Dam and the Terror Creek Reservoir. Therefore Rule 2.05.6(6xf) <br />does not apply to the Bruce Park Dam and the Terror Creek Reservoir as long as there is no material <br />damage or diminution of use. <br />However, as requested in comment number 4 above, the Division is requesting that a contingency <br />6