REV96904

• Permit No: C1980007
• IBM Index Class Name: Revision
• Doc Date: 8/27/1986
• Doc Name: USFS GRAZING SPRINGS CONCERN MT GUNNISON PERMT RENEWAL PN C-80-007
• From: MLRD
• To: TOM SCHREINER
• Type & Sequence: RN1
• Media Type: D
• Archive: No

Richard D. Lamm
Governor
DEPARTMENT OF NATURAL RESOURCES
Dared H. Gelches, Eneculive Director
MINED LAND RECLAMATION DI\
DAVID C. SHELTO N, Director
27 August 1986
T0: Tom Schreiner ~
FROM: Jim Pendleton
RE: USFS Grazin ring Concern - Mt. Gunnison Permit Renewal
(Permit No: C-80-007)
Pursuant to your request, I have reveiwed the subsidence-related comments
forwarded from the US Forest Service through Mel Shilling of the OSMRE-WTC.
The USFS is concerned that the springs which provide grazing water to the
livestock on USFS grazing leases be protected from damage due to subsidence.
This is a valid concern, even though I am surprised that the USFS has never
raised it during the past permiting reviews of the Mt. Gunnison No. 1.
Nonetheless, I offer the following response for your consideration.
The permit, as amended, includes a combined traditional survey and aerial
photographic subsidence monitoring program, which we have judged to be
adequate to monitor the mechanical response to subsidence. The purpose of
this plan is to verify those mechanical predictions included within the WECC's
application, which project maximum vertical subsidence and the associated
angle of draw. Further, the application contains a hydrologic monitoring
plan, which includes a spring monitoring component. WECC has agreed to
monitor a number of springs within the five year and life-of-mine permit
areas. We have also judged this plan to be adequate to protect the springs
inventoried by the applicant.
The USFS has included, in its comment letter, maps and a computer listing of
springs and ponds which they have inventoried above the proposed permit area.
I believe we must require the applicant to verify that all of the USFS
inventoried springs are included within their hydrologic monitoring plan. If
necessary, the applicant should either obtain agreement from the USFS to
forego monitoring of all inventoried springs or should amend their monitoring
plan to include any overlooked springs. Further, the applicant should
demonstrate, in response to USFS proposed stipulation 2, that the WECC
hydrologic monitoring plan will "...monitor those springs/ponds during the
period of possible subsidences at a frequency commensurate with risk of water
loss during actual and planned seasonal livestock use."
USFS proposed stipulation 3 is intended to ensure that WECC gets their
proposed "contingency plan" in place prior to projected subsidence (secondary
recovery) of any of the springs and ponds. I believe we must also require the
applicant to verify that this will be the case.
cc: Bob Liddle
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. [phone]