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~, <br />OSM Comments for the Draft Proposed Decision <br />and Findings of Compliance for Mt. Gunnison Hine, 320 Acre Modification <br />1. The text, on page 27, states that there is insufficient data and that <br />qualifying assumptions for application of the methods were not in <br />analyses of mine inflow and extent of the cone of depression caused by <br />mining, This inadequacy should be explained. <br />2, The text, on page 31, refers to consequences, "during the first five <br />years of mining***". It is not clear whether this section is referring <br />to the 5-year term now in effect or five years beginning with approval of <br />the proposed 320 acre modification. Please clarify. <br />3, The paragraph explaining Stipulation No. 8, on page 31, states that, <br />"The applicant has not considered the possibility of increased total <br />dissolved solids because of pond retention". This apparent inadequacy in <br />analysis of hydrologic consequences should be explained. <br />4, The Proposed Decision document should include a summary of the <br />analysis of the depletion of flow to [he upper Colorado River with <br />respect to the U.S, Fish and Wildlife Service's Windy Gap policy. We <br />understand that the applicant's response on depletion of flow was <br />submitted after this draft of the Proposed Decision document was <br />prepared. We have reviewed the applicant's submittal determining the <br />depletion of streamflow to the Upper Colorado River basin (UCRB), dated <br />April 22, 1985, The applicant appears to have included "precipitation <br />runoff" as an augmentation to streamflow in [he UCRB. Neither natural <br />runoff from unaffected areas of the permit area, nor treated surface <br />discharge from affected areas are factors in the computation of <br />depletion. Non-alluvial ground water made Sn the workings and discharged <br />to the surface-water system may be used to offset surface depletions. <br />5. The subsidence effects section (pages 33-37) should specifically note <br />that mining has not been approved and will not be approved in the <br />Minnesota Creek basin with this proposed decision. <br />