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' Grand Mesa Q Coal Company ~~~ ~ JU ~~CLA~A ~~pt`J151O~ ~~~~~,~ ~ P. O. Box 1351 Palisade, CO 81526 `1~19~a (303) 464-7951 July 6, 1988 Catherine W. Begej Mined Land Reclamation Division 423 Centennial Building 1313 Sherman Street Denver, CO 80203-2273 Re: Red Canyon Mine, File No. C-81-034; Permit Renewal Dear Catherine: Your letter of June 10, 1988, suggests means by which Grand Mesa might satisfy Rule 2.07.6(2)(d)Iv) for purposes of permit renewal. Grand Mesa believes that there are other alternatives for satisfying that rule under the current circumstances of the Red Canyon Mine, and particularly, that "consent waivers" from owners of occupied dwellings within 300 feet of the angle of draw of undermining are neither required nor appropriate under these circumstances. I will explain our reasoning briefly below and request the opportunity to meet with Mike Long, other appropriate Division representatives and you to discuss the situation. As you know, the mine was designed and underground mining was conducted in a manner to prevent subsidence. The details of the design and mine plan to accomplish this were contained in the operation plan and subsidence control plan of the original per- manent program permit approved by the Division. As you also know, mining ceased in 1984 and wil~ not be resumed because per- manent reclamation is in progress. No subsidence effects have occurred at the surface, which the Division has acknowledged by approving discontinuation of subsidence monitoring. With four years having passed, it is clear that the subsidence prevention design has proved successful, particularly in preventing material damage to any structures. Grand Mesa believes that two possibilities are available which would avoid the need to obtain "consent waivers." The first is