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Memo to Tony Waldron Bowie No. 2 Geotechnical Adequacy page 8 2.0 SUBSIDENCE IMPACTS 2.1 LAND USE I am puzzled by apparently incongruous statements within the application regarding land use. Stock ponds are mapped within the permit area. However, the entire area is categorized as being classified as "Wildlife Habitat". I can only surmise from the existence of the stock ponds that the area has been used for grazing of livestock and therefore classified as "Range Land" at sometime in the recent past. If so considerations such as sustainable animal units and walking time between water sources, including stock ponds, become appropriate topics for consideration. Subsidence impacts which would preclude the "Range Land" use might therefore constitute material damage and would require mitigation in the short term and long term. 2.2 SURFACE WATER The preparer proposes that "surface modifications of the surface drainage and ponds could be made in cases of any occurrence of subsidence cracks." This pragmatic approach would be acceptable if timely detection and implementation of the appropriate mitigative techniques can be assured. The applicant should propose a detailed inspection methodology to detect subsidence cracking impact to the potentially effected ponds and surface drainage ways. This should include inspection prior to the runoff season, during which the major diversion of surface runoff might occur. Further, in the case of the ponds and their antecedent ground or surface water sources, inspections should occur frequently throughout the stock watering season. These inspections should be completed in areas undermined for an appropriate period of time following retreat extraction, to verify negative impact from cracking. 2.3 GROUND WATER The position of the applicant presented throughout the application is that no significant water resources exist within the overburden or on the surface of the permit area. The Division's experience in the North Fork Valley suggests that many of the perennial springs and all surface runoff is appropriated. Potential disruption of any of the water sources requires a plan for augmentation approved by the water court. The experience of the Mount Gunnison No. 1 mine presents precedent for the resolution of these concerns. 2.4 BUILDINGS AND STRUCTURES The preparer did not address stock watering ponds within this section. The Division