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4. Currently, WECC has a plan far returning surface water intercepted by underground workings as follows: If major portions of surface waters are diverted underground by subsidence, this water will be intercepted underground, a hole from the surface will be drilled and cased and the diverted water pumped back to the surface. The underground diversion plan appears to be complicated by potential delays in obtaining a drill on short notice, drilling and casing in a subsiding area, and maintaining a functional well in this unstable ground. A review of WECC's water balance and water rights has indicated that WECC has sufficient water to mitigate most adverse impacts to surface water rights. If, however, due to subsidence, significant volumes of surface waters are diverted underground, there is some question as to whether the mitigation plan would quickly (within a week) restore this water to surface water flow, per Rule 4.05.15. WECC should submit a written discussion of the scenario of major diversions underground of surface water and its restoration to the surface system. This should include but rat be limited to time frames for obtaining a trained drill crew, drilling the connecting hole through subsiding ground, casing the hole and maintaining its integrity during pumping. 5. In Table 2.8.5A, several water rights were in the initial application stages during the permit approval period. Division review did not show documentation of the final resolution of these water rights. WECC should submit the necessary documentation to show the current status of these water rights in compliance with Rule 2.04.7(3). 6. WECC has surface water rights that are being used for the augmentation program if underground mining impacts the surface waters. WECC should indicate to the Division whether they are subleasing these surface water rights. If WECC is subleasing, please affirm that the contracts are worded to provide for rapid augmentation responses as is required by Rule 4.05.15. Yegetation - Rules 2.04.10, 2.05.4 (2 )(e ), and 4.15 The vegetation section of the Mt. Gunnison Mine No. 1 permit application was reviewed. One adequacy topic was noted and is outlined below. Use of a Similarity Index West Elk Coal Company (WECC) has proposed in Exhibit 4.6.1 .A (Volume 4) to employ a similarity index rather than a standard diversity index to comply with their reclaimed area species diversity requirement. While the argument is relatively compelling in favor of a similarity index, certain issues remain controversial while others have not been touched upon. The most obvious deficiency, listed as item (1) below, involves the lack of description in the narrative of Exhibit 4.6.1 .A of how WECC proposes to use the similarity index when comparing the reference and reclaimed areas. In addition to this, the Division is concerned about the use of the similarity index in a growth form