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Mr. Alan Belt November 9, 1992 Page 2 the permitted area is inclusive of all areas potentially i~acted by mining, and as the Long Draw springs fall outside of this area, the authority of the regulatory agencies involved (BLM and Q+!<i~) with regard to special stipulation "d" should not be extended to require that OWOC develop a water replaoe<oerrt. plan specific to these resources. CUVOC is sensitive to the concerns of the Stucker Mesa Domestic Water Co~any and is hopeful that a reasonable fir-r,,,; ~ can be developed to resolve this issue to the satisfaction of all parties. 4he primary concern of the Stucker Mesa Domestic Water ~Y is understood to be the lack of definitive knowledge regarding the ultimate source of water provided by the Upper Cabin Spring and the correspondug unknown potential for subsidence to impact the rersanroe. Limited hydrologic data fran the Upper Cabin Spring has been collected by Orchard Valley Mine personnel since 1983. 'Ihe data is generally indicative of an alluvial/wlluvial water system tharacterized by variable discharsJe related to seasonal rec3~arge of the system. Water c~~al ity fray the spring is oafarable to water quality typically encountered fran other alluvial/oolluvial arn,; fens in the area. No anaralous geologic features have been identified in the area which might suggest a ground~rater origin or connection for the spring. No areally extensive water bearing formations are known to exist in the area. 'ihe Long Draw drainage is, however, typified by several slumps arri landslide areas, particularly on the northwest side of the drainage, which are indicative of instability associated with saturated surficial deposits. 'Ihe Upper Cabin Spring is atypical as oa~ared to other monitored springs in the permit area in that measurable flaws appear to occur year arowxi aryl flow rates are relatively high. 'IY~e oc~aratively large drainage area (ammx;mately 440 acres) and enhanced subs~sface collection system installed at this site likely account for the consistent flow pattern observed. 'Ihe max,irnim flow recorded at the iMrr~wr Cabin Spring by Orchard Valley is 10.6 gpn 71pa~+rpr3 on April 9, 1992. 'Ihe Stucker Mesa Domestic Water Company has indicated that flows as high as 20 gpm have been measured. Flows in the ~~*- and fall months of 1991 and 1992 typically ranged fran 3 gpm to 6 gpm. Efforts are underway to iag~rove the monitoring capability at the Upper Cabin Spring by installing an in-line flow meter. OOVCC is oaanitt:ed to oollectilg and providing aoan_ate data on spring flow quantity arr] quality at the Upper Cabin Spring which can be used to docampnt any potential irgaacts. COVCC does not believe that mining currently proposed within the West Roatcap Creek watershed constitutes a significant threat to either the quantity or quality of water emanating fran the Long Draw springs at issue. Significant aryl potentially disruptive surface subsidence effects within the OOVCC permit area are anticipated only iIl areas where minim occurs below less than 800 feet of overburden. Consequently, buffer zones affording only limited coal extraction within certain areas of lease COC-37210 OOIItd1r1].Tg renewable re.,au'ce lards dr7d less than 800 feet of overl~nrden were defined within the permit area to protect surface resan•ces and prevent subsidence. As a frsther resour~c,~e-protective me~~~re, the western brnurlary of lease COC-37210 was wluntarily moved east to its present location in cooperation with and in response to ooncvrns wined bi'