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-3- 3. (con't) Additionally, Blue Ribbon Coal Company should amend their monitoring program to include a yearly submittal of a mine inflow map, description of mine inflows and mine inflow water chemistry. This monitoring of inflows and reporting of inflow data will satisfy the requirements for the mine to monitor the effects of mining on the hydrologic balance under Rules 2.05.6(3) and 4.05.15. 4. The Blue Ribbon mine received water rights to 15 gpm of water from the Hubbard Creek water well (Hubbard Creek Decree, Case No. W-3050), and storage rights for water stored in Blue Ribbon Reservoir No. 1 (Sediment Pond No. 1) under Hubbard Creek Decree, Case No. W-3051. With the four- fold increase in production rate from 50,000 tons/year to 200,000 tons/year, this water right (15 gpm) appears insufficient to cover the increased water required For cooling, dust suppression, fire protection, and domestic uses. Blue Ribbon Coal Company must provide to the Division an analysis of the water requirements of the mine and support facilities in light of it's existing water rights. If the water requirement of the mine exceeds the Decree, Blue Ribbon Coal Company should apply for additional rights. A water rights analysis is needed to find the applicant in conformance with Rules 2.04.7(3), 2.05.6(3)(a) and 4.05.15. 5. The applicant has supplied surface water baseline information for Hubbard Creek. However, to make the required written findings for Alluvial Valley Floors and cumulative hydrologic effects, the applicant should provide estimates of average flow and the mean annual yeild from the watershed (or the percent of flow contributed on an annual basis to flow in the North Fork of the Gunnison River). If the permit boundary correction shows that other perennial streams are located in or adjacent to the permit area, baseline data must be included for these streams as well. 6. The applicant has not included a site-specific statement of the probable hydrologic consequences of mining as required under Rule 2.05.6 (3)(iv). The assessment provided by the applicant (p. 120-123) was taken from the Colorado Westmoreland application. Although it is appropriate to use other applications as a guide for the analysis, the assessment itself must be a site-specific discussion of the probable hydrologic consequences of the proposed mining activities. The applicant should rewrite the statement of probable hydrologic effects to predict during-operation and post-mining effects of their operation (including possible subsidence effects) upon surface and groundwater. Alluvial Valley Floors - 2.06.8 The applicant has not supplied sufficient information for the Division to make an alluvial valley floor determination. Tlie information supplied is limited to the incorrectly defined permit area. However, the Division is required to make alluvial valley floor findings for the permit area and adjacent areas. The Division needs, at a minimum, the following reconnaisance-level, alluvial valley floor information for the permit area and adjacent areas.