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Mr. Larry Damrau ~ -4- September 23, 1982 . engineering information, to demonstrate conformance with the requirements of Rule 9.22.3(1)(d) and (e). The applicant has previously indicated to the Division that such design information and engineering analyses were being completed. The incomplete sections listed above must be addressed before the applicant is deemed complete and the review process progresses. If necessary, the Division would be happy to discuss these items in a meeting with representatives of Colorado Yampa Coal Company. Although not a completeness issue the question of federal lands needs to be addressed. The Foidel Creek permit boundary includes lands overlying federal coal. Specifically that portion of the permit area in sections 19, 31, 32, E'~W~f section 30 and the E'd section 32 T5N,R86W. CYCC is not planning to mine the federal coal during this permit term so it is not clear why these areas are included in the permit boundary. The inclusion of these areas ~dithin the permit area may subject the application to a federal review process. To simplify the federal lands issue CYCC should consider eliminating the land above the federal coal from the permit boundary or state clearly in the application the area is included within the permit boundary for surface access to monitoring sites, etc.. During completeness review several issues were identified which will become more apparent during the adequacy review. The application was not reviewed for adequacy but since some items wereidentified early it may be useful to mention the major items at this time. The discussion of probable hydrologic consequences needs to be expanded. The assessment needs to be more quantitative and should include the impacts of mining on the Fish Creek and Foidel Creek stream/alluvial aquifer systems. Both water quality and quantity could be affected. A prudent assessment would involve field investigations, laboratory analysis and the use of modeling techniques. On pages 2.05-50 and 2.05-51 of the application document, the applicant presents a discussion of the subsidence-related aspects of protection of the hydrologic balance. This presentation is inadequate as it exists, requiring more detail and justification for the conclusions presented. The applicant projects limits for overburden caving and fracturing above the extracted coal seam which are significantly less than observations contained in the current technical literature. Further, the applicant concludes that no adverse impacts of sub- sidence upon the hydrologic balance or water rights are anticipated from the planned underground mining activities. The applicant will have to further justify the assumptions concerning extent of caving, fracturing and hydrolyoic impacts. In addition, the applicant should develop a means of verifying projected effects upon the hydrologic balance. In specific, potential hydrologic effects upon tiie "overburden aquifer" and the Twenty-mile Sandstone aquifer should be monitored.