2013-10-16_REVISION - C1981041 (2)

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October 7, 2013 W eW Michael Boulay, P.G. Department of Natural ResourcesN Division of Reclamation, Mining, and Safety 101 South Td, Suite 301 Grand Junction, CO 81501 Re: Bond Release Application SL -8 on Permit No. C- 1981 -041 Section Rule 3.03.2 (3) indicates that, since we are likely to be adversely affected by the bond release, we have the right to file written objections. Section 5.02.5 indicates that, where we believe a violation may exist, an inspection may be warranted. We reference these rulings with respect to the bond release. After a review of the "Regulations of the Colorado Mined Land Reclamation Board for Coal Mining ", we would refer to the following sections: • 2.02.3 General Requirements indicates the necessity of a reclamation plan, including exploratory holes, existing drainage features, etc. • 2.04.5 General Description of Hydrology and Geology indicates the necessity of descriptions and /or maps for groundwater systems, discharges, overall hydrology, etc. • 2.04.7 Hydrology Description indicates the need for a description of ground water hydrology, ownership, and information pertaining to developed water resources. Developed resources could include "streams, lakes, ponds, springs, constructed drains, and irrigation ditches." • 2.04.12 Prime Farmland Investigation applies to surface mining, but may define prime farmland to include: land that has been historically used as cropland, or has a developed irrigation water supply • (9) Return of coal mine waste to abandoned workings refers to retainment of water underground, treatment of water if released to surface streams, and the effect on the hydrologic regime. • 2.05.6 Mitigation of the Impacts of Mining Operations sub (3)Protection of hydrological balance refers to applicants describing the rights of present users to surface and ground water, including "whether the operation would interrupt, diminish, or contaminate water sources." It also addresses a "hydrologic reclamation plan" to address adverse hydrologic consequen- ces, including remedial measures to prevent damage. Also a plan for the restoration of the approximate recharge capacity. • Sub(6) refers to a "Subsidence Control Plan." To include a detailed description of subsidence damage which could result from the occurrence of subsidence related phenomena... including consideration of the following: renewable resource lands, changes which make it technologically or economically infeasible to restore the productivity of the affected renewable resource lands.