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<br />• Enclosure 1 <br />Initial Review Comments <br />Little Middle Creek Tract <br />Colorado Yampa Coal Company <br />1. The life-of-mine area described on page 2.05-1 and shown as Map 10 <br />does not include the entire area permitted under Colorado permit <br />C-81-071. The Little Middle Creek Tract application consists of a <br />permit revision to permit C-81-072 and a mining plan modification <br />to obtain approval to mine on a recently obtained lease. The <br />applicant should be aware that any impact assessment, including the <br />cumulative hydrologic impact assessment, will assess Energy No. 1, <br />Energy No. 2, Eckman Park and the Little Middle Creek areas as one <br />life-of-mine area. <br />2. The applicant should provide a calculation of the amount of water <br />that will be depleted from the Colorado Review system by this <br />additional mining in order for the U.S. Fish and Wildlife Service <br />to determine a contribution to the Conservation Fund for Endangered <br />Fishes of the Upoer Colorado River. <br />3. The probable hydrologic consequences (PHC) section does not discuss <br />the spoil springs that have developed in the spoil. Discussion <br />should be added that expiains how the earlier analysis on hydrology <br />was incorrect and how the current PHC analysis handles the error. <br />This should include descriptions of overburden material <br />unsuitability and how it is being handled. <br />4. The application should contain information that "demonstrates" that <br />this is a thick overburden mine under Colorado rule 4.14.5. This <br />information should include data that confirms a 28 percent swell <br />factor. <br />5. The applicant indicates on page 2.05-92 of the permit application <br />that there will be significant "effects" on off-site ground water. <br />This should be explained further with respect to Colorado rule <br />34-33-120(2)(j) which requires minimizing impacts to the ground <br />water outside the permit area. <br />6. Previous permitting reviews at Eckman Park revealed several <br />wildlife species of interest to the U.S. Fish and Wildlife Service <br />in the area and a major concern over the elk calving habitat. <br />Map 5 should be revised to include locations of important wildlife <br />habitat features, as is indicated on the legend to the map. <br />0843M <br />