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5. Baseline water quality and water level data do not appear to be available for the North Portal Area. Page 41 of the PAP states, "all of the formation units in the Roadside southern permit area are above the river level and are recharged only in response to local precipitation, and are, therefore, relatively dry." No mention is made of the Roadside North permit area. However, page 60 of the PAP states, "where the sandstone and coal beds dip below the Colorado River, they receive recharge from it, are saturated, and therefore are considered aquifers. Where these beds occur higher than the river level, they are not completely saturated, and receive recharge only from local precipitation events. In this case, the strata are not considered aquifers." Exhibit 24 shows that, in the Cameo permit area, the Rollins Sandstone, which immediately underlies the Cameo B seam, dips below the elevation of the Colorado River. Therefore, it would seem logical ,in infer that the Rollins Sandstone is an aquifer beneath the Cameo mine workings. In accordance with Rules 2.05.6(3)(b) and 4.05.13(1)(b), monitoring of groundwater quality and quantity should be conducted at the Roadside North Portal Area. Please incorporate a monitoring plan into this revision. 6. Exhibit 5 depicts that Roadside will be undermining Coal Creek and Jerry Creek within this permit term. Please provide the Division with surface water information for Coal Creek and Jerry Creek locating all springs in accordance with Rule 2.04.7(2)(a). Please provide the Division with a spring and seep monitoring plan in this technical revision application. 7. Please provide the Division with the minimum, maximum and average flows which identify critical low flow and peak discharge rates for Coal Creek and Jerry Creek in accordance with Rule 2.04.7(2)(b). Surface monitoring flumes should be placed upstream and downstream in Coal and Jerry Creeks with continuous flow monitors. Please provide the Division with the location of the surface monitoring flumes on Coal Creek and Jerry Creek and a proposed surface water monitoring plan in this technical revision application. 8. Page 55 of the permit states that the inflow of groundwater at the Roadside South Portal mine has been monitored. The mine inflow monitoring should be carried over to the Roadside North Portal area. The mine inflow survey is a simple mapping and recording of localized inflows and sump accumulation. Please incorporate monitoring of the inflow of groundwater at the Roadside North mine .in the permit text.