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S L:-8) <br />J. E. STOVER & ASSOCIATES, INC. <br />2352 NORTH 7T" STREEET, UNIT B <br />GRAND JUNCTION, COLORADO 81501 <br />PHONE: (970) 245 -4101, FAX: (970) 242 -7908 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />October 21, 2013 <br />Mike Boulay <br />Division of Reclamation, Mining & Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Re: Snowcap Coal Company <br />Bond Release Written Objection <br />Permit C- 1981 -041 <br />Dear Mr. Boulay: <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />RECEIVED <br />0C1 `L 4 N13 <br />DMM � N� ANA SAFEIY�ON <br />Mr. Rudolf Fontanari, Jr. filed a written objection to Snowcap Coal Company's bond release application <br />SL -8 by a letter to the Division of Reclamation Mining and Safety (DRMS) dated October 7, 2013. Mr. <br />Fontanari believes he is likely to be adversely affected by the bond release. A meeting was held at the <br />mine site with Mr. Fontanari on September 18, 2013. Mr. Fontanari explained most of his concerns <br />during the meeting to Mike Boulay with DRMS and Jim Stover and Tonya Hammond representing <br />Snowcap Coal Company (SCC). On behalf of SCC following are its comments regarding Mr. Fontanari's <br />objections. <br />1. Mr. Fontanari alleges subsidence features have been apparent on the surface and continue to <br />develop periodically. <br />SCC - Surface subsidence is an accepted impact of coal mining. In some cases subsidence <br />features such as fractured cliff faces and irregular surface contours can be apparent on the <br />surface long after mining is complete. Most subsidence occurs shortly after mining is complete <br />and the remaining residual subsidence occurs within two to three years after mining. The short <br />timeframe for the effects of subsidence is confirmed by a DRMS policy memorandum dated April <br />13, 1987 regarding release of liability of areas overlying underground coal mine workings. The <br />policy memorandum states that for areas of extraction the liability period shall be a minimum of <br />three years after mining. The underlying point of this policy memorandum is that most, if not <br />all, subsidence occurs within three years after mining. <br />2. Mr. Fontanari alleges subsidence features cross perceived permitted boundaries, indicating a <br />potential misidentification of extracted resources. <br />SCC - During the onsite meeting, Mr. Fontanari explained that he believes a prior operator <br />mined some coal which it did not have the right to mine. Mr. Fontanari has expressed this <br />