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Page 12 <br />shall include a subsidence monitoring program designed to determine the accuracy of the <br />subsidence prediction required by Section 2.05.6(6)(e)(i)(D). <br />The application is, by exception, in compliance with this rule. The subsidence survey determined <br />that there might be a diminution of reasonable foreseeable use, and I believe there would be <br />material damage to Dove Cave. <br />Rule 2.05.6(6)(e)(iv) If the subsidence survey determines that material damage or diminution of <br />reasonable foreseeable use could result in the event of subsidence predicted to occur within the <br />permit and adjacent area, or if the Division determines that such damage or diminution could <br />occur, the application shall include a subsidence control plan as described in Section <br />2.05.6(6) (f). <br />The application is in compliance with this rule. A subsidence control plan begins on revised page <br />2.05-107. <br />Rule 2.05.6(6)(f) A subsidence control plan, prepared by appropriately qualified professionals, <br />shall contain the following information: <br />The GEI reports of Volume X bear stamps of a Colorado Registered Engineer. The letter <br />addendum of May 22, 2003, does not, but it is signed by a PE. None of the reports of Exhibits <br />15, 16, 17 or 18 bear certifications, or disclose who prepared them. <br />Rule 2.05.6(6)(f)(i) A description of the physical conditions, such as depth of cover, seam <br />thickness, and lithology, which affect the likelihood or extent of subsidence and <br />subsidence-related damage; <br />A statement is made on revised page 2.05-107 that depth of cover data is presented on Map 27. It <br />isn't. Such depths are presented on Figure 1 of Exhibit 17. I cannot read the seam thickness of <br />I Z- the E seam on figure 2, Page 4, Exhibit 16. Seam thickness is given as 10 to 20 feet on page 6 of <br />Exhibit 16. Excavation height was given as 9.5 feet (page 16, Exhibit 16). Lithology is presented <br />in Exhibit 16. <br />Rule 2.05.6(6)(f)(ii) A detailed description of the mining method and other measures to be taken <br />which may affect subsidence including: <br />Rule 2.05.6(6)(f)(ii)(A) The technique of coal removal, such as longwall mining, room and pillar <br />removal, hydraulic mining or other methods, including the size, sequence, and timing for the <br />development of underground workings as required by Rule 2.05.3(2)(b); and <br />The application is in compliance with this rule. Longwall mining is proposed (revised page 2.05- <br />108), as is room and pillar (2.05-108) with pillar extraction, and mine development (room and <br />pillar) without pillar extraction or reduction. Timing is indicated on Maps 14 and 14B.