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was homesteaded. A short distance downstream an old corral was observed We then proceeded into Morgan Gulch to the west. Irrigation ditches are present on portions of this Gulch in the center of section 14, T4N R94W. There is no question in my mind that this area is an AVF. We observed the area at the intersection of Straight Gulch and Morgan Gulch. I took a picture from the benchmark elevation 6639 in section 22, T4N R94W (pic morg strt intersect). We did not visit an area above this location along Morgan Gulch at the boundary of section 21 /22 that appeared to be an extension of the AVF below. We proceeded up Straight Gulch to the center of section 33, T4N R94W at the confluence of the west fork of Straight Gulch (pic straight Gulch). Here the water emanated from the west cutbank of Straight Gulch, likely subsurface flow from the west fork of Straight. The flow was estimated at 5 gpm and the EC was measured at 1600 umhos/cm. It is my opinion that Straight Gulch above its intersection with Morgan is not an AVF. The valley floor is sloped fairly steeply towards the stream channel and the valley is very narrow, and the stream channel deeply incised. We then proceeded to the possible location of a "fill" in Little Collum Gulch. Along the way we passed an alluvial well installed by the operator. The operator has yet to install a surface casing to protect the well from damage. All wells will be capped and locked upon completion. We stopped in Little Collum about % mile below the planned pit. This area would approximate the toe of an out-of-pit fill (pic valley fill). Along the west wall of the gulch, about 60 feet above the valley floor, was a small spring that emanated from a coal seam. Travertine deposits were noted in this area. The spring measured about 2200 umhos/cm, the highest EC value recorded during the inspection. Conclusion Morgan Gulch up to at least section 21, T4N R94W is an AVF without question. Collum Gulch downstream of section 26 should be studied further as initial evidence suggests it is also an AVF. The reservoir up Morgan Gulch should be investigated as to its potential role in past irrigation practices. The reservoir could also be a source of water to dilute possible mine water springs in lower Morgan Gulch from Phase III mining in the future. Additional comments reaardina long-term conseouences to AVF areas While long-term consequences may not be realized for 10-20 years into the future, nonetheless, the CHIA requires life-of-mine impacts to be estimated. In the event spoil springs develop and spoil water is discharged into Little Collum, Collum, and Straight Gulch, AVF areas on Morgan Gulch below Straight and Collum Gulch could be impacted. Additionally, Morgan Gulch enters the Yampa River immediately above an expansive area of AVF on the Yampa River. It will be important to understand the current and future contribution of Morgan Gulch waters to this AVF area on the Yampa River. (see enclosed map)