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Key Documents <br />Documentation provided by GCC related to water supply includes the following items, many of which were <br />prepared for the State of Colorado Division of Water Resources to obtain the necessary rights to divert and <br />store water: <br />1. Safe Yield Analysis, November 16, 2015 <br />2. Substitute Water Supply Plan, October 8, 2015 (under review by State) <br />3. Water Right Case No. 2007C W 100 (approved by State) <br />4. Water Right Case No. 2015CW3059 (under review by State) <br />5. Water Lease Agreement between GCC and Huntington Ranches, November 12, 2015 <br />6. Huntington Pond Construction Plans, November 15, 2015 <br />7. Harris Water Engineering memo, November 16, 2015 (the data provided in previous Harris memos <br />in the project file is outdated and not reflective of the current proposal) <br />8. CDPHE approval of Drinking Water Construction Plans and Specifications, May 8, 2015 <br />Note that the January 29, 2016 narrative provided by GCC contains outdated, or inaccurate, information <br />regarding water supply. Corrected information includes that groundwater wells are not proposed and a new <br />water rights application was filed on September 30, 2015 (with a Substitute Water Supply Plan submitted on <br />October 11, 2015); the November 16, 2015 Safe Yield Analysis by Harris Engineering contains the current <br />water supply and demands estimates; and the primary purpose for the new water rights application, and dry -up <br />land, is that the existing water supply did not produce an adequate quantity of water for current operations, <br />and additional supply is needed. The information contained in the documents listed immediately above, and <br />summarized below, reflect correct information. <br />Water Demands <br />The primary water demand at the site is that which is needed for dust suppression within the mine (to meet <br />required levels expressed by MSHA). As discussed above, dust suppression is accomplished by a continuous <br />miner machine, with a constant mist being applied to the coal as it is extracted. Dust suppression additionally <br />occurs on the roadways within the mine and the conveyor belt carrying coal out of the mine. This demand is <br />proposed to be met using untreated raw water. <br />A much smaller water demand occurs within the bath house, which requires domestic/treated water for <br />employee showers, bathroom, boot wash, and other uses within the building. <br />GCC reports that it used 30 acre-feet (AF) of water in 2014 and may have a need for up to 40 AF. Of this, <br />domestic demands cannot exceed approximately 2.5 AF, as wastewater from the building cannot exceed 2,000 <br />gallons per day (GPD) based on the San Juan Basin Health Department onsite wastewater system permit for <br />the upper leach field serving the bath house. <br />Water Supply <br />GCC's Safe Yield Analysis states that the 2007 water court decree assumed the mine demands would be <br />approximately 13 AF, which would result from a demand of 20,000 GPD over a four-day work week based on <br />experience at the King I mine. The 2007 decree allowed for three sources of water (1) Huntington dry -up of 9 <br />acres; (2) La Plata River diversions; and (3) groundwater wells, though only the Huntington dry -up supply has <br />been put to use. GCC has not exercised its La Plata River diversion right, which is relatively junior and would <br />be delivered via the Hay Gulch Ditch. GCC has also not constructed groundwater wells in order to avoid <br />concerns with impact to area hydrology. <br />Diversion records show that GCC diverted approximately 11 AF per year from 2012 to 2014 with its dry -up <br />right. Therefore, a significant gap remained between GCC's exercised supply of approximately 11 AF and its <br />target demand of approximately 40 AF. To meet this demand, GCC filed for dry -up of an additional 44 acres <br />Project No. 2012-0089 PC <br />4852-5627-2942, v. 3 <br />Page 6 of 32 <br />(DM, VS, DP) <br />