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extraction ratios, measures taken to prevent or minimize subsidence and related damage, areas of <br />full extraction..." As we read this rule, it is clear to us that the key word is "plan" - that this rule is <br />asking for information on where the permittee proposes (i.e. plans) to mine. A plan or design is <br />needed so that the subsidence effects can be evaluated per this performance standard. The plan is <br />submitted, studied, and approved first — then the mine workings are developed by the mine operator <br />as they've proposed or planned. Simply, a map of as -built (i.e. already completed) workings are not <br />Ip ans or proposed workings — they are actual completed workings, and thus are not what this rule <br />requires. <br />MCC has complied with this rule by providing revised Map 51 and revised Exhibit 60E in the <br />application for TR -124. Together they include MCC's proposed potential plans for mining the E -seam <br />and the other information and subsidence evaluation required by this rule. We agree that providing <br />an as -built map of the workings that have actually been mined is of value to the Division to ensure <br />that the areas mined are part of an approved plan and have been sufficiently evaluated for <br />subsidence impacts. Again, we are not opposed to providing an informational mining progress map <br />on a regular basis, but do not believe that this rule requires as -built workings be submitted as revision <br />applications — it requires that changes to the plans for mining be submitted as revisions. After TR- <br />124 is approved, MCC intends to mine in accordance with its approved plans for mining and if <br />changes in the plans are needed, another revision application will be submitted. <br />xathy 'Welt, <br />Environmental Engineer III <br />Mountain Coal Company, LLC <br />West Elk Mine <br />P.O. Box 591 <br />Somerset, CO 81434 <br />Phone (970) 929 -2238 <br />Cell (970) 433 -1022 <br />Fax (970) 929 -5050 <br />** *Email Disclaimer: The information contained in this e-mail, and in any accompanying documents, may constitute <br />confidential and /or legally privileged information. The information is intended only for use by the designated recipient. If <br />you are not the intended recipient (or responsible for delivery of the message to the intended recipient), you are hereby <br />notified that any dissemination, distribution, copying, or other use of, or taking of any action in reliance on this e-mail is <br />strictly prohibited. If you have received this e-mail communication in error, please notify the sender immediately and <br />delete the message from your system. <br />