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. ~• <br />3. The applicant must provide a statement which specifically addresses the <br />anticipated hydrologic consequences of the proposed mining activities. This <br />discussion must address all issues identified in 2.05.6(3)(b)(iv) based <br />on all available data. This statement should individually discuss possible <br />effects to the quantity and quality of surface water and ground water during <br />and after mining. <br />2.05.6(6) Subsidence Survey, Subsidence Monitoring and Subsidence Control Plan <br />Section 2.1.6 of the permanent program permit application includes the <br />statement that; "convergence data and observation of rib stability obtained <br />to date during exploration activities have shown no abnormal movement". The <br />application should include data to substantiate the applicant's subjective <br />judgement of "normal movement". Further, this section of the application <br />states that, because the work in this permit term (five years) will include <br />only development work, which will preclude subsidence, no subsidence <br />' monitoring is planned for this permit term. This subjective opinion should <br />also be better supported by data or literature references within the <br />application. Minor subsidence may occur and a properly designed monument <br />monitoring system could allow the collection of valuable rock mechanics <br />data which could be utlized in subsidence prediction for future permit <br />operations (2.05.6(6]). <br />A determination of the presence of renewable resource lands is contingent <br />on the receipt of appropriate baseline data as specified in other portions <br />of this correspondence. <br />2.06.8 Surface Coal Mining and Reclamation Operations on Areas, or <br />to Areas, Including Alluvial Valley Floors <br />With regard to alluvial valley floors (AVF's) a minimum amount of information <br />that is acceptable to the State of Colorado includes the following (2 A6.8)(3)). <br />This information should be supplied for the mine and loadout. <br />1. In light of the controversy over the adequacy of the current ground water <br />data Sheridan Enterprises must first define the ground water system in the <br />area proposed to be mined. with an understanding of the ground water system <br />and surface waters in the area Sheridan Enterprises must quantitatively <br />Justify the ground and surface water adjacent areas. <br />2. Once the adjacent area is defined and all valleys holding streams are <br />appropriately mapped two approaches to a permit may be taken. First the <br />applicant may affirmatively demonstrate the presence of an alluvial valley <br />floor based on available data or second, submit sufficient field data (re- <br />connaissance Ievel AVF study) to enable the Division to make an evaluation <br />regarding the existence of the probable alluvial valley floor in the adjacent <br />area and to determine which areas, if any, require additional information <br />for the Division to make a final AVF determination (2.06.2(3)(b)). The first <br />option could be a less rigorous demonstration to show that an AVF exists while <br />the second approach would be a more rigorous justification why an AVF does <br />not exist. <br />3. A reconnaissance level alluvial valley floor study is required from the <br />operator. This study should comply with section 4.24 of the regulations <br />and should include a map of the total life of mine area (on a USGS 7~j minute <br />(10) <br />