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1993-11-05_GENERAL DOCUMENTS - C1981038
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1993-11-05_GENERAL DOCUMENTS - C1981038
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Last modified
1/30/2021 5:10:42 PM
Creation date
11/23/2007 9:23:09 AM
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DRMS Permit Index
Permit No
C1981038
IBM Index Class Name
General Documents
Doc Date
11/5/1993
Doc Name
Federal Lease Permit (COC-53356)
Permit Index Doc Type
Other Permits
Media Type
D
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No
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determine if post-mining subsidence will affect the flow. The <br /> lessee must be held responsible for replacing any lost or polluted <br /> water with domestic water of equal or better quantity and <br /> quality, or, as this is not so easily done, for compensating <br /> homeowners for their loss of equity. (See below.) <br /> In your EA, P. 12, V, MITIGATION MEASURES, you discuss <br /> a buffer zone protecting East Roatcap creek and a water <br /> replacement plan for irrigation water. However, no mention is <br /> made of protection of off-lease domestic water or of replacement <br /> of any lost or polluted domestic water. No mention is made of <br /> the original buffer zone on the west which was delineated largely <br /> to protect our water supply. I find this strange since one of <br /> our representatives, Linda Lindsey, spoke to Betsy Daniels in <br /> August about this and she was assured that the BIM was quite <br /> aware of the origins of the buffer zone and of the need for <br /> protecting our water supply. <br /> The mitigation section does require the lessee to "conduct <br /> and provide to BLM an inventory of all existing state adjudicated <br /> water rights in and adjacent to the lease tract which may be <br /> impacted by subsequent mining activities. . ." Yet it only <br /> requires that "existing cross-tract and on-tract water flows <br /> • shall be maintained by the lessee even following release of the <br /> permit bond by the Colorado State Mined Land Reclamation Board. <br /> The problem, as we see it, is that our water source may very <br /> well be disturbed by any mining at the top of Long Draw, yet no <br /> protection is offered to us because our water is not "cross- <br /> tract or "on-tract." Do you see what we mean?" Does the BLM <br /> think that a coal mine should be allowed to disrupt the domestic <br /> water supply for an entire mesa with impunity? <br /> To reiterate, we believe that, since the true source of our <br /> domestic hater supply lies at an unknown depth, the BLM's <br /> approach to protecting our water should be based on a worst-case <br /> analysis. What Would happen if, due to subsidence, our water <br /> disappeared? <br /> Under your section on Water Resources, Page 11, you state <br /> that "Mitigating measures have been incorporated that are <br /> designed to provide complete protection of the surface and <br /> groundwataer resources in and adjacent to the tract. .. . As I <br /> have just noted, however, your mitigation section does not deal <br /> with our domestic water at all. This is because, if you will <br /> recall, it Was determined at the time of the original lease, that <br /> it was a practical impossibility to replace our domestic water if <br /> it were lost. There simply are no other known sources of <br /> domestic water available to our mesa. It was for this reason that <br /> . the BLM required the buffer zone. <br /> If the BLM is now going to permit mining in the buffer zone, <br /> this means that you need to deal with our domestic water question <br /> and try again to come up with mitigation measures. what would <br /> happen if, due to subsidence, our water disappeared? Perhaps a <br />
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