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Mr. Alan &alt November 5, 1992 Page 3 the Stuckex Mesa Danestic Water Company during the original lease tract delineation prooe`ss. Projected mining in the lease COC-37210 modification area arri new lease ~C-53356 tract does not call far undergraud development to oocis in any closer proximity to the Long Draw springs than that projected for the existing lease COC-37210 area. Mininq in the nearest proximity of the springs will be located at a m;n;,m m, of 1700 feet distant fran the surface P ~~~ion and wllection point of the Upper Cabin Spring. ~Yre lease modification area occurs wholly below arrT outside of the watershed defined by the location of the Upper Cabin Spring though most of the area (approximately 35 acres) is located within the West Roatcap C.Yeek drainage. Subsidence projections developed by Geo-Hydro Consulting, Inc. in 1983 are known to be reasonably conservative and have been verified thrargh subsidence data collection efforts wrducted subsequent to the study. 'Itre worst case impacts based upon the subsider~oe projections contained in that study do not entail significant and lasting impacts to colluvial aryl alluvial water sources lIr areas of greater than 800 feet of overburden. 'IYre Upper Cabin Spring is located ove~x 1000 feet of overburden while mining in the nearest proximity will occur under approximately 1300 feet of overburden cover. A water repplaeement plan conceptually acceptable to the Studcex Mesa Danestic Water Ca~any is being developed bi' COVCC in an effort to alleviate their concerns regarding a stable long-term water replacement supply. 03VOC believes the development of an acceptable replacement plan provides the most expedient resolution of this issue. 'The plan gP*+A*ally consists of four phases. First, monitoring of the Upper Cabin Spring will be increased to provide a more congrlete database aryl basis of crng~arison for detecting impacts. Second, in the unlikely event that flow fran the Upper Cabin Spring is completely and s++~P*+ly disnrpked ar noticeably diminished as a result of mining, repair procedures as detailed in CMLRD Perrtut No. C-81-038, Volume 3, Subsidence Repair Hans uc~;C, will be implemented. 'Third, in the event repair efforts are unsuocassful, steps will be taken to e,ctP~d the pipeline now serving the Orc3~ard Valley West Mine south to a point at which water frorn a Steven's Gulch water well of o~nparable quality, quantity, and seniority can be introduced into the Stucker Mesa Dwnestic Water Cwigrany's pipeline as a replacement supply. are particular water right proposed for initia:L replacement consists a water lease which C~7CC holds the rights t0 until the year 2027. Fauth, repair efforts will e~rtinue at the original source of the Uppex Cabin Spring. However, if water replacement needs wntinue beyond the year 2027, COVCC will arrange prior to that time through the filing of an augmentation plan to have water withdrawals fran the Steven's (Ulrh well atx~+nted with water rights wholly owned by COVCC. As an example, shares owned in the North Fork Farmers Ditch could be utilized far this purpose. Zb i~rlement the third and fourth phases of this plan, certain rights~f~.ray ar easeumnts would creed to be obtained for the pipeline aryl water oast proceedings would need to be finalized. Given the highly speculative nature of any replaoecnent scenario developing, Cr7VCC questions the degree to which specifics of the plan need to be developed at this point. Special stipulation "e" attached to coal le~cse COC-37210 rnrnii res the lessee to filr'rri 5L1 information to BLM 47t1id1