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plan is to avoid exposure of groundwater during mining operations, and Allen has no plans to <br />"use or store" any exposed waters. <br />5. The Application Need Not Include A Substitute Water Supply Or Augmentation <br />Plan. <br />Objectors incorrectly suggest that Allen's application is incomplete because it does not <br />include a substitute water supply plan or augmentation plan for the proposed well. The Boazd's <br />Rules are cleaz that, in order to be complete, an application need not include all other permits or <br />licenses Allen will require for its operations. Instead, Allen must provide a statement setting <br />forth which other permits, licenses and approvals Allen either "holds or will be seeking" in order <br />to conduct its proposed operations. Rule 6.4.13. Gary Thompson's April 13, 2006 <br />correspondence, (Exhibit 35), which was provided to the Division in response to its first <br />adequacy review, cleazly states that Allen will use an on-site well for water supply, and "Allen <br />plans to obtain appropriate water rights for operation of the well pursuant to a blanket <br />augmentation plan sponsored by the Upper South Platte Water Conservancy District and the <br />Center of Colorado Water Conservancy District." Contrary to Objectors' assertion, the fact that <br />a finally approved substitute water supply plan or augmentation plan was not attached to the <br />application is immaterial to whether the application is complete. Allen is certainly awaze, as <br />acknowledged in prior correspondence with the Division, that appropriate water rights approvals <br />must be in place prior to well construction. <br />