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,~ :~iC ~, .'.1 ~ i~ -.i- np Y'1l U, ICJ JJ :n addition, the Division has identifYe~i in the amendurJ application inadequacies tnaL tr1Bre nuC aph~rznt prc'•ious to Lhe current suo~uittal ur drat have evolved since Lhe draft findings document a;as written. Although some of these issues may be ne~-, they are serious issues that :cast be rasolv~d either witiYin the context of Lhis permit review or as perntic stipulations that impose strinyer.L timz frames for compliance. The Division's primary concerns with the permit application are round in the hydrology sections. Ilydreloyic concerns have iieen an issue Chrouyhout the review proczss and uecausc of Ct,is, CPie issue deserves some explanation in this letter. Tuz Division is required by Section 34-33-114(2)(c) of Lne Colorado :,urface Coal d7ininy kucla~uCiun Act to make an assessn~ent of the probaule cunu,lativc nupacLS of all anl.icipatc~l cual ruining in i.hc ~Icncr.~l area u,~ tae nydruloyic balance arnJ to make u Iindiny Chat Lhe uperaCions proposed under the application have been designed to prevent damage to the nydrdloyic balance outside the permit area. In order to make this finding there are three uasic canponents that are to ue audressed by Lhe applicant in the permit application in accordance with sections 34-33-11U and 121. These are: 1) a description of the hydrologic system; 2) a projection uy Lhe applicant of what impacts Che mining operation will have on the hydrologic system; and 3) a demonstration by the applicant that the operation has been designed to minimize disturbance to tide hydrologic ualance during and after mining. Specifically, the Act states the fallowing: Section 34-33-110(L)(k) - The permit application shall include the follo:•,iny:...The name of the watershed and location of the surface straam or tributary into which surface and pit rJrainage will oe discharged; Section 34-33-11U([)(1) - The permit application shall include the follo.vir~y:...A determination of thz probable hydrologic consequences of the surface coal mining and reclamation operations, both on and off the mine site, witn respect to the hydrologic regime and the quantity and quality of water in surface and ground :,ater systems, including the dissolved and suspended solids under seasonal flow conditions and the collection of sufficient data 'For the mine site and surrounding areas, so that an assessment can be made by the division of the probable cumulative impacts of all anticipated mining in the area upon the Hydrology of 'the area and particularly upon water availability; Section 34-33-121('Z)(i) - each permit issued under this article and rclatin, to the unueryround coal ~nir~iny shail require the rperator to:...F~iiii~nize the disturbances of the prevailing Hydrologic balance at the mine site and in associated off-sitz areas and to the quantity of surface water and ground water systems both during and after underground coal mining and rJuriny reclamation by: