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Permit Revision Adequacy <br />July 6, 2004 <br />Page 16 of 18 <br />mapping on Minnesota Creek, but based on the description, it appears that the correct reference <br />would have been to the west section line of Section 2, T14S, R91W. This apparent error was <br />incorporated into the Division's subsequent findings documents. Please address this apparent <br />error, and amend the narrative reference as appropriate. <br />114. Narrative in pazagraph 3 on page 2.06.4 indicates that the operator will "...refine the <br />subsidence control plan for the mining area under Dry Fork" and further states that an <br />augmentation plan is being developed that "...when finalized, will detail mitigation efforts for <br />short and long term effects to water rights holders should unforseen factors affect the hydrology <br />of Dry Fork". This narrative appeazs to be outdated. <br />a) Please update the narrative as appropriate to summarize the aspects of the currently <br />proposed SOD mining plan and subsidence control plan that will be implemented to <br />preserve the hydrologic balance of those portions of the Minnesota Creek basin within <br />the proposed permit area. Please include reference as appropriate to detailed plans and <br />designs in other sections of the application. <br />b) Please address the measures that will be implemented to prevent material damage to the <br />quantity of water in surface water systems that supply the alluvial valley floors on <br />Minnesota Creek. Please include, as appropriate, measures that will prevent stream <br />dewatering associated with undermining of the Dry Fork and its tributaries, and Lick <br />Creek, and measures to prevent damage to the Deep Creek Ditch and any other water <br />supply ditches that are located within the SOD permit azea. <br />c) Please update the status of the augmentation plan, and include reference to the <br />appropriate section of the application. <br />115. On amended page 2.04-143 there is revised language indicating that riparian vegetation and <br />wetlands in the SOD permit azea extension would not be measurably disturbed by underground <br />mining. <br />Please address the measures that will be implemented to prevent dewatering of the alluvial <br />aquifer along Dry Creek associated with undermining. In addition, please address the effect <br />that ground surface lowering associated with longwall mining is anticipated to have with <br />respect to wetland water levels, and discuss the probable associated changes in the extent and <br />nature of wetland azeas and wetland species composition. <br />116. Rule 2.06.8(4)(a)(iv) also requires submittal of information to demonstrate that the operation <br />would not materially damage the quality of water in surface or ground water systems that <br />supply identified alluvial valley floors. Please address within the AVF section of the <br />application, the potential for minewater discharge to affect water quality suitability of waters <br />used to imgate the identified alluvial valley floors on the North Fork of the Gunnison River. <br />The assessment should be based on worst case projection for both the short term (maximum <br />discharge projected during operations) and the long term (maximum discharge from flooded <br />workings via designed discharge and other connections between the flooded workings and the <br />North Fork stream alluvial system). The projections should incorporate the effects of proposed <br />