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<br />Page 17 <br />As concluded under Rule 2.05.6(6)(b)(ii) above, no material damage from subsidence is <br />anticipated for the Bruce Park Dam. However, no description of a subsidence-monitoring <br />program as required has been incorporated into the PAP. A monitoring program is required <br />by a special stipulation to the BLM lease (page 3) as well as our Rules. The program covers <br />before, during, and after mining. The stipulation includes consultation with the (Colorado State <br />Engineer) Dam Safety Engineer. Recommend this detailed plan and consultation be made a part <br />of the PAP. <br />Rule 2.05.6(6)(f)(vi) Appropriate maps, prepared according to the standards of 2. 10, showing <br />the underground workings, the location of any facilities or structures proposed for subsidence <br />control, and the location and extent of areas in which planned-subsidence mining methods will <br />be used including all areas where measures will be taken to prevent or minimize subsidence and <br />subsidence-related damage. <br />The application includes Maps 14, 14B, and 27. <br />Rule 2.05.6(6)(f)(vii) A schedule for the submittal of a detailed plan of the underground <br />workings, as required by Rule 4.20.1(3). <br />The application is in compliance with this rule by exception. The map is already provided. <br />Rule 2.10.3(1)(k) See the Rules for the text of this rule. The revised Map 27 should be legend to <br />indicate that portion of the B seam already mined. See also Rule 2.04.3(3)(c). <br />Rule 4.20.1(1) Underground mining activities shall be planned and conducted so as to prevent <br />subsidence from causing material damage to the surface, to the extent technologically and <br />economically feasible, so as to maintain the value and reasonably foreseeable use of surface <br />lands. This may be accomplished by leaving adequate coal in place, backfilling, or other <br />measures to support the surface, or by conducting underground mining in a manner that <br />provides for planned and controlled subsidence. Nothing in 4.20 shall be construed to prohibit <br />the standard method of room and pillar mining. <br />The application is in compliance with this rule with, perhaps, the undermining of Dove Cave. <br />Rule 4.20.1(2) See the Rules for the text of this rule. This rule is a performance requirement. <br />Rule 4.20.1(3) At the time of revision to a permit, or for permit renewal, to the extent not <br />previously submitted, the operator shall submit a detailed plan of the underground workings. <br />The plan shall include maps and descriptions, as appropriate, of significant features of the <br />underground mine, including the size, configuration, and approximate location of pillars and <br />entries, extraction ratios, measures taken to prevent or minimize subsidence and related damage, <br />areas of full extraction, and other information requested by the Division for good cause shown.