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B. The Division finds: <br />(a) The applicant has presented, as part of the permit application in accordance with Rule <br />2, specific, reasonable plans for the underground mining operations (4.22.3(a)); <br />(b) The proposed underground mining is necessary or desirable to assure maximum <br />practical recovery of the mineral resource and will avoid multiple disturbance of the <br />surface (4.22.3(b)); <br />(c) The applicant has satisfactorily demonstrated that the plan or revision for the <br />underground mining activities conforms to applicable local and State <br />requirements for underground mining and that the permits necessary for the <br />underground mining activities have been issued by the appropriate authorities <br />(4.22.3(c)); <br />(d) The areas proposed for the variance have been shown by the applicant to be <br />necessary for the proposed underground mining (4.22.3(d)); <br />(e) No substantial adverse environmental damage, either on- or off-site, will result <br />from the delay in completion of reclamation as required by 4.22 (4.22.3(e)); and <br />(f) No provisions have been made for the off-site storage of spoil that require <br />compliance with 4.09 (4.22.3(f)). <br />X1I. Impacts from Subsidence <br />Section 2.05.6(6) of the permit application contains information on predicted impacts from <br />subsidence. PSCM predicts no subsidence will result from the proposed mining because the <br />underground mining will be limited to room-and-pillar mining in which the pillars will not be <br />removed. PSCM predicts there will be no impacts to structures or renewable resource lands <br />from subsidence. The permit application contains a monitoring program designed for <br />verifying the predictions of no subsidence and no impacts to structures or renewable resource <br />lands. The monitoring program includes inspections of underground workings for roof-falls <br />and pillar degradation, and surveying the following structures and renewable resource lands <br />that are proposed to be undermined: Routt County 27, concrete footers of electric <br />transmissions lines, Boedekker Reservervoir #15 (a 0.5-acre stock pond), and the thalweg of <br />Grassy Creek. Map 2.05.6-M 1 shows the monitoring locations. Hydrologic monitoring will <br />be conducted in Grassy Creek upstream and downstream from the undermined area, as <br />shown on Map 2.04.7-M 1. All monitoring includes a premining and postmining survey. All <br />structures except Boedekker Reservervoir #15 will be monitored during mining. The <br />Division finds the monitoring program is adequately designed for detecting subsidence <br />impacts and proposes to approve the program. <br />Peabody Sage Creek Mine 34 May 7, 2010