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~` ~ • <br />Page 2 <br />current permit boundary, but has not yet been wnetructed and requires U.S. Forest Service <br />Special Use Permit approval before it can be constructed. MCC has obtained many yeah of dau <br />in this drainage from the existing, tower Sylvester Gulch flume. The problem u that deydopmdtt <br />mining ~ occumd and ~ occur in this drainage (par the wrrart approved mine plBaand <br />within the wrrerrt approved pemtit boundary) before one year of baseline data cat- be obtained <br />from Shit site. MCC proposed the site to monitor the impacts of iptgpyg~jpjpg the Brut panel in <br />this area (as longwall mining is what orgy cause sutthce impacts). The flume site wiU be <br />underatined by the second longwall pond planned to be mined. Since this site will provide only <br />limited data end if the Division insists that one year of data must be obtained from thu site prior to <br />any further mining, MCC may consider ddetmg the site from the proposed monitoring program. <br />MCC agrees that development mining could affect aquifero, but ea the permit dowment presorts, <br />no aquifers exist within or adjacent to the permit area. Devdopment mining would not impact the <br />sur6tce, especially with deeper overburdeq u no subsidence ocwrs. MCC believes that it is not <br />ttaaooable for the Division to disallow 91- mining, especially development mining. MCC has <br />baseline data from Sylvester Gulch, but not from the new, proposed flume. Agaiq having the <br />necessary baseline data was one of the primary issues considered by MCC apd the Division when <br />we togotber proposed the Apache Rocks boundary. MCC'e continued operations, withithe <br />approval of this application, depends on the ability to proceed with devdopment mining; If <br />devdopment mining is allowed, one year of baseline data is not an issue. ~~. <br />9. The potemial wetlands impacts from mining are provided on page 2.05-155 and 15G <br />Generally, u no surface disturbance is proposed in this application, no impacts to wetlands are <br />anticipated. Also, with the relativdy small flows associated with the wetlands, the probable <br />hydrologic impact from mining beneath these resources is projected to be insigni5csnt. The <br />concerns expressed in the original question (re: Rule 2.05) have been addressed in the permit <br />document. "~ <br />a~ <br />~, <br />Requesting a map of the wetland areas appears to be a baseline (or Rule 2.04) cottcern`bttd MCC <br />does not believe that such is required to address Rule 2.05 in this question. MCC has cbnducted <br />5eld verified delineations and mapping of wetiend end riparian areas in tits Apache Roche permit <br />revision area and the remainder of the Box Canyon lease tract. MCC can provide a coppr of thin <br />delineation for the Division's files. This map and the table provided in the last submittal are <br />accurate and require ody minor editorial corrections to be finalized, but at this time, both are <br />marked as drafts. <br />22. See response Nos. 2 and 3, above. MCC believes that the baseline monitoring commitments <br />on pages 2.04-ti0 and 2.04-% are realistic, reasonable and achievable. With the monitoring <br />commitments in the permit dowmant, ie it neuaeary for the Division to stipulate it too,? <br />41. Sce response Noe. 2 and 3, above. '~ <br />Soils (Rule 2.04.91 +~i <br />I <br />/ 1. MCC incorrectly copied Table 22 as Exhibit 22. The Table has ban wrrected to b,~ Exhibh <br />27 and copies are attached. Tha Division's previous letter had requested a reference to Exhibit <br />~I <br />