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4. For a holistic, permit -wide evaluation of the risk of <br />future coal mine fires as a result of subsidence and the <br />creation of new oxygen pathways to abandoned or <br />worked out mine workings. We do believe that everyone <br />would agree that once started such fires are difficult and <br />expensive to extinguish. <br />5. For an integrated approach and evaluation of the effect <br />of mine subsidence and mine interception of <br />groundwater and the resulting impacts on surface <br />irrigation, flood irrigation, and the ability to irrigate. This <br />would include impacts on ditches, canals and pipelines, <br />and, further, the the interception and exfiltration of <br />waters through the (aging) mine drainage system with <br />an emphasis on restoring and stabilizing flows in Rapid <br />Creek and Cottonwood Creek. The evaluation should <br />include a data driven analysis as to whether the existing <br />monitoring well and its gage are functional and <br />optimally effective in measuring mine interception and <br />discharge to the Colorado River. <br />6. For a determination as to whether Snowcap remains in <br />compliance, or has fallen out of compliance, with permit <br />conditions and reclamation standards; <br />7. The original permit predicted little or no impact on the <br />alluvial valley floors of Rapid and Cottonwood Creeks. In <br />connection with the water exfiltration issue described <br />above, Fontanari seeks a determination as to whether <br />continued deterioration of the underground workings <br />since the cessation of active mining operations has <br />increased the impact or threat of impact on the alluvial <br />valley floors of the referenced creeks. <br />Page o8 <br />