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<br />-3- <br /> <br />The application tontalns inadequate details for assessing the Impacts of these <br />facilities. The assessment of mining impacts should be quantified, and the <br />analyses used 1n assessing each projected Impact should be Included in the <br />application. <br />The applicant should address the probable hydrolo9lc consequence of each facet <br />of the mining operation so that the following questions are answered: <br />a) what areas the applicant is going to disturb, <br />b) what the hydrologic characteristics of disturbed and ad,}acent areas <br />are (the present hydrologic balance), <br />c) what the type of disturbance is (1.e., cut and fill, subsidence}, <br />ej how the disturbances affect the hydrologic balance, <br />e) what specific measures the company will take to minimize impacts to <br />the hydrolo9lc balance in disturbed areas. <br />2. The applicant has not adequately addressed the effect of subsidence on <br />surface water. At a minimum the applicant should address changes to <br />stream gradients and Increased inflows of surface water to the <br />underground system. <br />Subsidence - Rule 2.05.6(6) <br />1. The techntcal projection of subsidence theorizes a mechanism which <br />limits subsidence generation to gob formation on a panel by panel <br />basis. No consideration 15 given to potential stoping of gob materials <br />downdtp Into subsequent lower panel levels. Considerable elaboration <br />upon the anticipated mechanism of subsidence will be necessary before <br />the application can be considered adequate. Secondly, the Division 1s <br />concerned that much of the area of protected significant vertical <br />subsidence (14' maximum) 1s comprised of steep sloped ridgetop area, <br />which might be sub,}ect to significant secondary mass movement phenomena, <br />as a result of subsidence disruption. It will be necessary for the <br />applicant to prepare feasible methods of detection and mitigation, in <br />order to assure prevention of material damage to the affected and <br />ad,}oining permit areas. A significantly more complex subsidence <br />monitoring program will be necessitated by the above concerns. <br />Alluvial Valley Floors - Rule 2.06.8 <br />1. Based on the information contained in the permit application it appears <br />that the Division will find that the Colorado River's alluvial terraces <br />and alluvium within and ad,}acent to the permit area are alluvial valley <br />floors (AVF's). <br />Additional Information is needed prior to making the required written <br />alluvial valley floor findings. The necessary additional information <br />includes: <br />