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. W~sti~'I~ T~~~ <br />`~a~~~` TJNITED STATES DEPARTMENT OF THE INTERIOR III IIIIIIIIIIIII III <br />FISH AND WILDLIFE SERVICE sas <br />ECOLOGICAL SERVICES <br />0 <br />Western Colorado Otlice ~ ~ <br />~~ <br />529 25 iA Roed, Suite &113 <br />^~^' Grand Junction, CO SISOSfi 199 + ~' <br />PHONE: (303) 243-2778 FAX: (303) 245-6933 <br />RJ REPLY REFFJ2 TO: <br />ES/CO:OSM-CDMG <br />MS 65412 GJ <br />RECEIVED <br />February 23, 1993 <br />MAR 11993 <br />Christine Johnston, Reclamation Specialist Olv~sionofMineralsrt,Geology <br />Colorado Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Subject: West Elk Mine's water depletion estimation <br />Ms. Johnston: <br />The Fish and Wildlife Service (Service) received a letter dated January 31, <br />1993 that outlined water depletions due to mining activity by the West Elk <br />Mine (WEM). The Service is appreciative that WEM has calculated the water <br />depletion, however, we disagree with WEM's estimate. We agree that WEM is <br />using 81.3 acre-feet of water annually; however, we do not agree that two <br />return flow items should be subtracted from depletion estimates. WEM has <br />listed 46.7 acre-feet of surface flow as an addition to the upper Colordo <br />River basin (UCRB) as well as 5 acre-feet of groundwater. Both the <br />groundwater and the surface runoff are water inflows to the UCRB that would <br />occur whether the WEM was operating or not. It appears that the only reason <br />WEM included these return flows was because they have physically moved the <br />water into pipes or ditches and have some idea of the quantity of water that <br />flows on parts of their mine. There is 15.3 acre-feet of water WEM uses for <br />its operations that is treated at a wastewater treatment plant. This is the <br />only water that appears to be returned to the UCRB from the water that has <br />been depleted. Therefore, the SCf~ti~1l.C'~ estimata of water depletimt is (8i <br />acre-feet) - (15.3 acre-feet) = 66 acre-feet. <br />Furthermore, the Service is puzzled as to why WEM diverts 282 acre-feet <br />annually when it only uses 81.3 acre-feet annually. Either WEM is using more <br />water than it has reported or WEM is pumping water unneccesarily. <br />Once again, the Service is appreciative of WEM for providing information on <br />water depletions but the Service recommends that WEM recalculate water <br />