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Page 13 <br />Rule 2.05.6(6)(f)(ii)(B) The location and extent of areas in which planned-subsidence mining <br />methods will be used, including all areas where measures will be taken to prevent or minimize <br />subsidence and subsidence-related damage. <br />The application is in compliance with this rule. Planned-subsidence methods and prevent <br />measures are portrayed on Map 27. <br />Rule 2.05.6(6)(f)(iii) A detailed description of the measures to be taken to prevent subsidence <br />from causing material damage or lessening the value or reasonably foreseeable use of the <br />surface, including: - <br />The application is in compliance with this rule. See discussions beginning on revised page 2.05- <br />107. <br />Rule 2.05.6(6)(f)(iii)(A) The anticipated effects ofplanned subsidence, if any; <br />The anticipated effects of planned subsidence are described. See discussion starting on revised <br />page 2.05-109 and map 27. <br />Rule 2.05.6(6)(f)(iii)(B) Measures, if any, to be taken in the mine to reduce the likelihood of <br />subsidence, including such measures as: <br />Rule 2.05.6(6)(f)(iii)(B)(I) Backstowing or backfilling of voids; <br />No such measures are proposed. <br />Rule 2.05.6(6)(f)(iii)(B)(II) Leaving support pillars of coal; and <br />Leaving support pillars is proposed. See revised pages 2.05-108 through 2.05-114. The Hubbard <br />Creek Entries and areas mined under Hubbard Creek are to be protected by limiting the areas to <br />development work (areas of limited extraction). Areas with less than 110 feet of overburden are <br />protected the same way. Openings through faults are to be protected. Limited extraction zones <br />protect pond P-1, the bleeder entries and vent shaft in the vicinity of Freeman Gulch. Portions of <br />Hubbard Creek and the Hubbard Creek road are to be protected by a limited extraction zone. <br />Identification of Dove Gulch and Dove Cave as protected by limited extraction zones on <br />revised page 2.05-117 conflicts with other parts of the application. I believe Dove Cave needs <br />to be so protected to meet the Dove Cave requirements of the coal leases. The BLM lease states <br />that perennial portions of Dove Gulch need to be protected. Exhibit 19 does a good job of <br />demonstrating that it is not perennial. With the concurrence of the BLM with this determination, <br />Dove Gulch need not be protected. The entire review and coordination might be incorporated <br />into the PAP. Also, the State Historical Officer (SHPO) has cleared Dove Cave, but the lease