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It does not appear at the present time that the applicant has provided the required baseline studies of surface and ground water, acid mine production analysis (if pyrite is present), and operational and reclamation features that will protect surface and ground waters from pollution. A complete review of the sources and pathways for any contaminants to reach surface and/or ground waters must be conducted. Until all of this information is forthcoming, the applications is incomplete and cannot be approved. We suggest that if field analysis determines that acid production is possible, then additional static and dynamic tests should be conducted to more fully ascertain the potential for acid production. Proper attention should be made to ensure that testing is done under conditions which include the presence of thiobacillus ferroxidans and that short-term neutralization reactions in the sample do not skew the results towards an overly optimistic acid neutralization/production ratio. In any event, the Division should not complete its review of the application until all long-term kinetic and batch tests have been completed (i.e., at least 20 weeks). Another important concern regards the potential for the local clay to release phosphorus (primarily via sediments) to the Arkansas River system. Much of the clay in Colorado does contain phosphorous. Eutrophication of reservoirs and lakes in the system is a serious problem as evidenced by NWCCOG's 1996 white Paper on the subject. The White Paper was based on the Health Department's Section 305(b) report. It noted that 9 out of 12 publicly owned reservoirs/lakes on the Arkansas were eutrophic. The Division should ensure that the Parkdale Project does not in any way contribute to this problem. The Project's proposed sedimentaticr. pcnds raise a number of questions as well. First, has the applicant applied for an NPDES permit for the .discharge from these likely unlined ponds into the Arkansas system? The fact that the ponds may first seep into local groundwater before reaching a surface stream does not disqualify the ponds as point sources under the Clean Water Act. What sediment loading will result from the ponds? Along these lines, what are the short and long-term operation/maintenance/treatment costs associated with these ponds/berets? Under state law, such costs must be included in the required bond before the application can be approved.