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MID-CONTINENT RESOURCES.INC. <br /> 201 Centennial St.Suite 406 <br /> Gleurood Springs. Colorado 81601 <br /> OW)945-4958 <br /> July 12, 1985 <br /> Ms. Candace Thompson <br /> Mined Land Reclamation Division <br /> 423 Centennial Building <br /> 1313 Sherman Street <br /> Denver, CO 80203 <br /> Dear Candace: <br /> Mid-Continent Resources, Inc. requests that the subsidence <br /> monitoring program for the Coal Basin mines be suspended indef- <br /> initely. There simply are no valid reasons to continue this <br /> costly program. <br /> When the permit application was prepared in 1980 in compliance <br /> with the MLRB Regulations for Coal Pining, the case was made that <br /> there were no structures nor renewable resource lands above the <br /> underground workings that would require further concern with <br /> surface subsidence. This reasoning was not accepted by MLRD <br /> staff members on the ground that grazing lands and aquifer recharge <br /> areas existed along the Huntsman Ridge area above the underground <br /> workings and should be identified as renewable resource lands. <br /> The 14LRD determination that there are renewable resource land <br /> above the Coal Basin mines seems quite spurious when considering <br /> that the surface elevations above the mines are between 10 , 500 <br /> and 11, 850 feet, grazing in that unusually rough terrain is <br /> limited to a few sheep, elk and deer during three of four summer <br /> months, and underground aquifers are highly unlikely within the <br /> upper reaches of Huntsman Ridge. <br /> Based on the MLRD decision that there were identifiable renewable <br /> resource lands above the underground workings, Mid-Continent <br /> Resources, with the assistance of a consultant, prepared and <br /> submitted a subsidence program consisting of the inventory of the <br /> renewable resource lands, description of worst possible consequence <br /> of subsidence on the renewable resource lands, description of <br /> damage or diminution of reasonably forseeable use of renewable <br /> resource lands which could result from subsidence, and a subsidence <br /> monitoring program. An additional requirement in the permit <br /> application was for the company to make a determination statement <br /> of the effects .of subsidence, if it did occur, on material damage <br /> or diminution of reasonably forseeable use of renewable resource <br /> I <br />