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., The applicant identifies large areas of Cliff House outcrops up gradient of Coal Gulch. It is felt that the Cliff House Sandstone is capable of, and indeed does transport and store measurable quantities of water. This water is probably transported and contained in a basal sand of the formation under semi-confined conditions. Underlying shales in the Menefee and overlying shales in the confining units restrict the vertical component of flow. The semi-confined nature of this system dictates that ground water flow is controlled by dip direction, topography, and lithology. Probably, the major component of flow is towards the Sheep Springs Gulch area, with some flow movin more south, southeasterly toward Cherry and Coal Gulches. It is possible that this component of the flow regime is controlled by the Perins Peak Syncline, south/southeast of the proposed permit area. Subsidence of mines could cause bed separation and bulking into the lower Cliff House. At the very least, fractures will cut into this formation. The disruption of the continuity of the Cliff House would induce mine inflows from the postulated aquifer system. Fracturing or bulking would, in effect, be creating zones of high secondary permeability, thus redirecting local ground water flow potentials toward the abandoned mine. As the mines slope up-dip, a very easy flow path to the portal, and then to the surface water system, is established. Subsidence is likely to occur at the proposed mine site upon abandonment. It is reasonable to assume that the mechanics of the failure will be the same as at the Victory No. 1 mine site. It is also reasonable to assume a worst case portal discharge from the proposed mine to equal the maximum measured portal discharge at Victory No. 1. Likewise, quality should be equivalent to that portals discharge. In addition, if it is assumed that the Victory No. 3 Mine extracted the 'A' seam, then fracturing at the surface may be expected with as little as 260 feet of overburden. Use of worst case figures confirms this. If bulking migrates upward for 30 times the mined height of 6 feet, and if bed separation continues for another 11 times the mined height, subsurface subsidence will continue upwards for 246 feet. Since fracturing has been documented through 260 feet of overburden, it is not unrealistic to expect that fracturing will occur through 300 feet of overburden. Therefore, subsidence effects may be expected to intercept the first ephemeral drainage upstream of the proposed portal. The drainage is within a zone of probable subsidence from 350 feet above it's confluence with Coal Gulch to a point approximately 2000 feet upstream. Peerless Resources has committed to a mine plan in which pillars will not be extracted beneath any surface whose elevation is 7400' (300 feet of overburden) or less. By leaving these pillars in place, the dewatering of the first ephemeral drainage above the portal, and its associated colluvial aquifer system, will be minimized. Minimizing the amount of mine inflow will