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<br />Also an evaluation of the chance of finding further rock art or rock shelter
<br />sites in the potential subsidence areas needs to be addressed. A general
<br />overview of the historic period of the area is needed; including fur trade,
<br />early settlement, development of mining, agriculture, railroads, etc.
<br />3. The prehistoric background is adequately covered in the submission however
<br />the later historic periods are not addressed. An understanding of the area's
<br />historic development (fur trade, early settlement, development of agriculture,
<br />coming of the railway and mineral exploration including coal) is integreal
<br />to understanding the cultural resources of the mine plan.
<br />4. Disturbed or potentially disturbed areas need to be clearly documented
<br />with maps and legal descriptions, and the relationship of the culture
<br />resources to these areas clearly defined.
<br />5. An expanded discussion of potential impacts (both direct and indirect) and
<br />resultant protective measures to be employed to minimize or prevent impacts
<br />is needed on a site specific basis. Impacts may include vandalism, subsidence
<br />and erosion; and a discussion on measures to mitigate or prevent these impacts
<br />to specific sites is needed. These measures may include avoidance, fencing,
<br />excavation, etc. The sites in question are 5GF741, 5GF742 and 5GF743.
<br />2.04.5 General Description of Hydrology and Geology
<br />The applicant has not provided sufficient information to characterize adequately
<br />the geology and ground water in the proposed permit area and adjacent area. In
<br />particular, without a sufficient characterization of the ground water it is not
<br />possible to assess the impacts of mining upon water resources, upon the rights
<br />of water users in the area and whether alternative water supply information is
<br />needed. Also, it is not possible to makeadetermination of the probable
<br />hydrologic consequences of the mining operator ((34-33-120(2)(1)) to assess the
<br />impacts of mining upon potential alluvial valley floor (34-33-120(2)(j)(VI) and
<br />potential subsidence effects upon renewable resource lands (34-33-121(2)(a).
<br />The major deficiency is the lact of quantifiable data. Therefore, at a minimum,
<br />the applicant must submit the following:
<br />2.04.6(1)(b)(i)(D) The roof and floor analysis is insufficient. It appears
<br />that the analysis is only in the two feet of coal which will be left in the
<br />mine. This is deficient in two respects. One is that it does not characterize
<br />potential rock waste material and the other is that it does not help characterize
<br />potential water quality problems.
<br />2.04.6(1)(b)(i)(E) The applicant has not provided the following coal analyses
<br />data: sulfate, pyrite, total sulfur, organic sulfur, pH, Iron, Manganese,
<br />Calcium, Chloride, Flouride, Plagnesium, Nitrogen {Nitrate), Phosphate, Potassium,
<br />Sodium, Sulfate, Conductivity, Sodium Absorption Ratio, Total Carbonate,
<br />Arsenic, Barium, Boron, Cadmium, Chromum, Copper, Lead, Mercury, t4olybdenum,
<br />Nickel, Selenium and Zinc. The applicant will need to submit this data. See AtF~l. o.(
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<br />2.04.6(2)(a)(V) The applicant needs to submit additional descriptions of the
<br />surface and underlying geology for the areas in the permit area which are or
<br />will be affected by surface operations and facilities. This includes describing
<br />how sloughing of road cuts and face-ups will be controlled.
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