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Page 6 <br />b Terror Creek road (portion). I found no description. A general description is on page 43 of <br />Exhibit 15. <br />Rule 2.05.6(6)(b)(ii) If the description of worst possible subsidence consequences, prepared in <br />accordance with Section 2.05.6(6)(b)(i), determines that no material damage or diminution of <br />reasonably foreseeable use could result in the event of mine subsidence within the permit and <br />adjacent areas, and if the Division concurs with that conclusion, the application shall include a <br />monitoring program designed to determine the accuracy of that conclusion, as described in <br />Section 2.05.6(6)(c). <br />There is no specific determination that no material damage or diminution of reasonably <br />foreseeable use could result in the event of mine subsidence within the permit and adjacent areas <br />in the PAP. For features identified above as such: <br />Hugh cabins located along Terror Creek. I found no monitoring program designed to <br />determine the accuracy of this conclusion. <br />Terror Ditch. I found no monitoring program designed to determine the accuracy of this <br />conclusion. <br />Curencanti-Rifle 230/3435 KV electric transmission line (power line). I found no monitoring <br />program designed to determine the accuracy of this conclusion. <br />Terror Creek road (portion). I found no monitoring program designed to determine the <br />accuracy of this conclusion. <br />Terror Creek. I found no monitoring program designed to determine the accuracy of this <br />conclusion. The closest longwall mining in the D seams has already been accomplished (west <br />end of Panel WD3, Map 14). Mining of Panel B-3 is imminent. A survey monument monitoring <br />station between the point of nearest mining (including the gateways) and the stream, outside the <br />angle of draw, would have determined the validity of the prediction. Such a station might still be <br />set near the west end of the B-Seam 1 East Mains. Perhaps monitoring could consist of periodic <br />visual inspections. <br />The entries are very similar to standard room and pillar mining. See Rule 4.20.1(1) below. See <br />Rule 2.05.6(6)(c) below. Pillars protect them. In this review I took a "limited extraction zone" to <br />be a "first mining zone" with no "pillar slabbing" (page 2.05-110). "First mining" might be <br />considered a form of "room and pillar" mining. A concern is raised by the statement on page 1 of <br />Exhibit 15 that "Any room-and-pillar mining practices planned at the Bowie #2 Mine will not <br />result in total extraction." Partial extraction could include retreat mining, slabbing, and robbing, <br />and appears to apply to the panel gateways (retreat extraction is included in the mine plan on <br />page 2.05-116). The limited extraction zone needs to provide "long-term stability". <br />On page 32 of Exhibit 15, partial extraction zones are areas of main entries and panel <br />development pillars. On this same page, a 50-foot safety zone is provided, along with angles of <br />draw from the surface to the coal seam, to define such areas. Map 27A uses 100 foot safety <br />zones. A BLM lease stipulation is 100 feet along Hubbard Creek Road (44.05 Drive). Long-term