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features within the permit area. Repairs, if necessary, will be effected by the operator for <br />the ditch and have the approval of the surface landowners. This method has proved to be <br />effective as in early 1990, subsidence cracks traversed the Huntington Ditch and NKC <br />immediately effected repairs by placing an impermeable fabric liner down several hundred <br />feet of the ditch to repair the crack and prevent further problems if additional cracks <br />appeared. <br />No renewable resource lands lie within the permit area. Information provided in the <br />application indicates the Pine Gulch drainage, which at one time was suggested to be a <br />renewable resource area, does not in fact qualify as one. There is no aquifer or recharge <br />area for an aquifer in the Pine Gulch area. Core hole data supplied with the original <br />application demonstrate that the bedrock section above the level of the coal is dry. The <br />survey of wells and springs in the area of the mine has established stratigraphically lower <br />aquifers whose recharge areas do not include Pine Gulch. The Pine Gulch area is also not <br />one utilized for agricultural or silvicultural production of food and fiber nor does it serve as <br />a pasture land. The confluence of Pine Gulch and Hay Gulch approximately three miles <br />downstream from the mine was determined to be an alluvial valley floor on which <br />agricultural activities are conducted. These activities however, do not rely on the surface <br />or ground water resources originating in the Pine Gulch area. Provisions of the proposed <br />mining plan, furthermore, will minimize any potential for mining related subsidence <br />impacts on the Pine Gulch drainage. Elongated pillars will not be extracted during final <br />retreat. As a result, the Pine Gulch drainage area will be assured of continued long term <br />stability. <br />GCC predicts the worst possible consequences from subsidence caused by mining at the <br />King II Mine will be cracks in a two -track road and offset of a barbed wire fence on the <br />ridge west of the surface facilities area. As described in Section 2.05.6 of the permit <br />application, GCC has committed to inspecting the road and fence, filing a report with the <br />Division, and providing repairs if there is subsidence damage. <br />XVL Concurrent Surface and Underground Mining — Rule 4.22 <br />This section does not apply to the King Coal Mine permit application. <br />XVIL Operations in Alluvial Valley Floors — Rule 4.24 <br />A. The Division has determined that an alluvial valley floor exists within the affected or <br />adjacent area. Therefore, the following findings are in order for the alluvial valley <br />floor known as Hay Gulch located four to six miles southwest of Hesperus, <br />Colorado. <br />The King Coal Mine is the only active coal mining operation located within Hay <br />Gulch. Field observations by Division staff and information contained in permit <br />applications indicate that small areas of unconsolidated stream -laid materials are <br />present in tributary drainages, where the King I and King II surface facilities are <br />located. These smaller areas do not meet the size criteria for AVFs. <br />25 <br />