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b) Groundwater Rights Rule 4.05.15 requires that the operator "...shall replace the water supply of any owner of a vested water right which is proximately injured as a result of the mining activities in a manner consistent with applicable State law." The PAP addresses the potential for mining to impact existing groundwater rights (page 2.05.6 -28). Three pre - existing groundwater rights are described within the permit and immediately adjacent areas: the Corley Mine Well, the Corley Company Well, and the Thompson Well. The Corley Mine Well and the Thompson Well were each completed in old mine workings in the Rex Carbon seam, which is — 300' above the Vento seam and —400' above the disturbed interval. The Corley Company Well was completed in the Raton Formation, higher still in the stratigraphic column. As has already been discussed, there is a negligible chance that the Southfield mine could have dewatered the strata which the wells associated with these water rights are completed in. It should be noted that the PAP information is not entirely consistent with information. available from the Division of Water Resources (DWR). Information accessed using the Aquamap tool available through the DWR websiteb shows that there is a record of two groundwater rights within the area. The first is named the "Corley Mine Well" (WDID: 1205025) and corresponds to the location of the Corley Mine Well on map 12. The second is named the "Rex Carbon Drill Hole" (WDID: 1205680); it was decreed to John E. Thompson on January 24, 1974 and corresponds to the location of the Thompson Well on map 12. Note that a third structure, named "IL EFC 2" (WDID: 1205400) was inventoried by DWR but does not have an associated water right; this structure corresponds to the North Dewatering Well, which was latterly re- designated as MWNW and is discussed in detail below. The Division is unaware of any groundwater rights owned by South Central Land and Mining, LLC, or K2T, LLC, or any individuals associated with the Vento group. Rule 2.04.7(1 xb) requires that the operator shall "... also provide well locations and reported yields from all wells within the proposed permit and adjacent areas which are registered with the Office of the State Engineer ". On page 2.04.7 -13 of the PAP, table 11 contains a list of wells in the permit and adjacent area however it appears that the table may be out of date. Appendix A gives a list of well permit applications within 1 mile of the Southfield Mine permit boundary, downloaded from the DWR database on January 12, 2015. The list has been filtered to remove records where the permit application status is "abandoned ", "denied" or "expired"; where the owner is EFCI; or where the permit was issued after 2000 (when the mine was closed). The remaining list comprises 42 records. Please update table 11 of the PAP. If any wells have been damaged please describe the extent to which operations at the Southfield Mine impacted the well and any measures EFCI have taken to mitigate the impact. If replacement wells have been drilled, please include relevant information about them. RESPONSE: Table I I has been updated and is included in APPENDIX C " with this submittal. Only one water well is known to have been impacted by Southfield mining. Although uncertain if the Corley Company Well (No. 119459) went dry due to mining subsidence, in good faith and in responding to the landowners request. a new well was drilled for the Corley Company during December, 2014. Information on the new well, Permit No. 296198, is included in APPENDIX "C'. Another well (Thompson Well No. 22948) is listed in the PAP base line data as having the 'potential" to be impacted due to its location. However, records document that the Thompson Well was out of service prior to Southfield mining operations. 8