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draw should be increased to 190 and will revise Map 51 as such. <br />11. "The DRMS considers the proposed updating of Map 51 with only the Annual Reclamation <br />Report to be too infrequent for DRMS to adequately evaluate subsidence impacts. The <br />proposal to not update the permit copy of Map 51 would not meet compliance with Rule <br />2.03.2(1), which requires information in the application to be current. The DRMS reiterates its <br />original request to add to the permit application a commitment to submit along with each semi- <br />annual subsidence report an application for a Minor Revision that updates Map 51 with all <br />actual workings in the Projected Potential Mining Area." <br />MCC disagrees with the Division's application of Rule 2.03.2(1) as the basis for requiring MCC to <br />submit a minor revision twice a year to update Map 51 with the actual mined E-seam workings. <br />Keeping the map current with actual mined workings is an impossible task, because just after the <br />map is updated with the current mine workings, mining that occurs during the next mining shift will <br />cause the map to no longer be "current". Rule 2.05.6(6)(e)((F)(II) does not require that current mined <br />workings be provided on a map, but states that "the extent of the proposed mine workings" be shown <br />and per Rule 2.05.6(6)(e)((F)(III), also show "the ground surface areal extent of an area determined <br />by the proiction of the angle of draw, if predicted ... or 45', if no prediction..." MCC has already <br />provided this information on Map 51 (as revised per #10, above) and subsidence impacts have been <br />evaluated in Exhibit 60E, not on Map 51. In addition, MCC has provided and will continue to provide <br />Map 51 including current mined workings as a courtesy (as does 20-Mile Mine, we understand) <br />during inspections or otherwise upon request, and will provide another copy at the time of submitting <br />the Annual Reclamation Report if that proposed Rule change is approved. <br />Please contact me at (970) 929-2238 or by e-mail should you have questions regarding this submittal. <br />i;?? 1?? <br />Sincerely, <br />?? <br />Kathleen G. Welt, <br />Environmental Engineer III <br />cc: Doug Nolte - MCC <br />Dan Hernandez - CDRMS