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study (Volume IIIA, Exhibit 19) to demonstrate that Dove Gulch is an ephemeral, rather than a perennial drainage. GMUG interdisciplinary specialists including a hydrologist, wildlife biologist, range management specialist and geologist reviewed this study, and applied local knowledge to the known resource conditions in Dove Gulch. The result of this review is that the GMUG agrees that Dove Gulch is not perennial over the course of the drainage, however we do not agree that the drainage is ephemeral, rather it exhibits intermittent drainage characteristics. We believe that there is sufficient ground water issuing to the surface in portions of the gulch to create perennial conditions that supports the ecosystem. The GMUG has reviewed the subsidence effects analysis on Dove Gulch, and finds that given the thickness of overburden in the area, orientation of longwall panels and drawing from experience subsiding drainages in adjacent areas, Dove Gulch could be subsided without causing irreparable damage. Therefore, by this letter the GMUG is specifecally approves Dove Gulch as a location where mining that causes subsidence can occur, although as we have on-going interest in preserving theground-water supported ecosystem in Dove Gulch, we will need additional resource monitoring in this area. We would like to discuss additional monitoring with BRL and the Division. A longwall panel will be developed under Dove Cave. Federal coal lease stipulations (a)(4) and (i)(7) state that `the lessee/operator is required to take measures to ensure that Dove Cave is protected from the negative effects of subsidence, and that it's structural integrity is maintained'. BRL proposes to bolster Dove Cave with timber posts before mining within the angle of draw of the cave, and then leaving the posts in place for 2 years post-mining. While this may be plausible mitigation, the GMUG wishes to hold a field review with BRL and the Division at the cave to assess the effectiveness of this proposed method. Minine will be performed within one mile of Bruce Pazk Dam. Federal coal lease stipulation (f)(B) states "The lessee shall be required to perform a study to establish baseline conditions, . potential mining-induced seismicity and potential translated effects to the Bruce Pazk (Terror) Reservoir and dam, The study will be completed prior to any underground mining activity (including subsidence) within one mile of the Bruce Pazk reservoir and dam. The Lessee shall also be required to establish a seismic monitoring program to locate, measure and quantify the progressive and final effects of underground mining activities on the Bruce Pazk reservoir. The monitoring system shall utilize techniques which will provide a continuing record of change over time and an analytical method for location and measurement of a number of points over the lease azea. The study and monitoring program shall be developed in consultation with the Dam Safety Engineer, Colorado State Engineer's Office, water Division 4 and appropriate affected parties. Further, stipulation (f)(C) requires `Existing and permitted surface improvements will need to be protected, restored or replaced to provide for continuance of current land uses. With specific regard to the Bruce Park Reservoir and dam, should structural damage result from mining-related activities, the lessee shall be responsible for dam repair and compensation to the injured party or parties.