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October 11, 2011 Page 29 <br />of the Colorado Mined Land Reclamation Division (CMLRD) Regulation for Coal Mining. <br />According to New Elk officials, stream buffer zone signs have been placed in high- traffic areas <br />on -site and will be placed along the entire length of the Purgatoire River within the permit <br />boundary. <br />Planned Allen Seam mains to be developed under the alluvial bed will have seven 20 -ft- <br />wide entries and 65 -ft x 75 -ft pillars (center -to- center). The mains have an SF of 4.0, for <br />development in 4.5 -ft -thick coal at a depth of 500 ft. This geometry results in an extraction of <br />49 %. Other pillar designs may ultimately be considered, but in no case will the design ARMPS <br />SF be less than 2.0 and extraction ratio be more than 50 %. <br />No material damage to renewable resource lands has been recorded which can be <br />attributed to past mining at the New Elk Mine in the 1980s. No discernible effects can be <br />attributed to subsidence induced by the old New Elk workings, as evidenced by the stable <br />condition of the Colorado & Wyoming Railroad right -of -way and SH 12. Any effect of <br />subsidence on the renewable resource lands located in the Purgatoire River area is considered <br />unlikely, given the low extraction ratios and adequacy of cover depth between them and the <br />underground workings. In addition to the above - mentioned mining controls, the following <br />mitigation and monitoring plan is recommended. <br />4.14.2 Alluvial Valley Floor Monitoring Plan <br />To ensure that the control plan is effective, the following monitoring plan is <br />recommended: <br />• A pre - mining survey of the alluvial bed within a 10° angle of draw, from the planned <br />Allen Seam workings, should be performed to collect baseline alluvial morphology. <br />• Monthly visual observation of the alluvium within the monitoring area should be <br />performed once the development workings are within a 10° angle of draw, from the <br />planned Allen Seam workings, until 2 months after development has advanced directly <br />beneath. <br />• Any unusual, large crater or crack formation in the alluvium should be noted. <br />4.14.3 Worst Possible Consequences of Damage to Alluvial Valley Floor <br />Although unlikely, subsidence damage to alluvium could alter the river bed morphology <br />by creating large cracks and craters. This may lead to the onset of river bed erosion and loss of <br />alluvium from the affected areas. <br />4.14.4 Alluvial Valley Floor Damage Mitigation Plan <br />In case monitoring indicates the onset of damage or potential for damage to the alluvium <br />in the Purgatoire River bed, the following mitigation plan should be adopted: <br />• <br />Appropriate. personnel at mine and regulatory authorities should be informed in case <br />anomalies are observed that may indicate the alluvium is being affected. <br />Agapito Associates, Inc. <br />