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The Applicant's most recent submission states: The objective of the groundwater and surface water monitoring plan is to establish recognizable trends in water quality such that any deviation from the established characteristics is recognizable. The established trends will be developed over a 13-month period, prior to startup of commercial operations. This will be accomplished by water level measurements and water quality analyses (monitoring) of a network of groundwater wells, surface water stations, and production facilities (pg. 1). .rr The groundwater monitoring program is broken into two principal periods, a baseline period and a commercial operations period. The baseline data collection period includes five quarters proceeding the startup of commercial operations as specified by the Colorado Department of Natural Resources, Division of Minerals and Geology (DMG). Baseline period requirements aze that eight measurements be taken in afive-quarter period. During commercial operations, the frequency of monitoring measurements will be reduced as per discussion in section 3.3 (pg. 9). This plan cannot be the basis for granting a permit due [o statutory limits on the authority of the DMG to approve a permit application from the Applicant before the Applicant has completed its baseline studies. The statute provides that, "Reclamation permits for mining operations shall be obtained as specified in this article." § 34-32-109 (1). "After June 30, 1976, any operation proposing to engage in a new mining operation must first obtain from the board or office a reclamation permit as specified in this article" § 34-32-109 (2). "Mining operation" is a defined term. It "means the development or extraction of a mineral from its natural occurrence on affected land." § 34-32-103 (8). "Development" is likewise defined. It "means the work performed in relation to a deposit, following the prospecting required to prove minerals are in existence in commercial quantities, but prior to production activities, aimed at, but not limited to, preparing the site for mining, defining further the ore deposit by drilling or other means, conducting pilot print operations, constructing roads or ancillary facilities, and other related activities." § 34-32-103 (4). "Affected land" is also a defined term. It "means the surface of an area within the state where a mining operation is being or will be conducted, which surface is disturbed as a result of such operation. Affected lands include, but shall not be limited to private ways, roads...and railroad lines appurtenant to any such area; land excavation; prospecting sites; drill sites or workings; refuse banks or spoil piles; evaporation or settling ponds; leaching dumps; placer area; tailings, ponds, or dumps; work, parking, storage or waste discharge areas; and areas in which structures, facilities, equipment, machines, tools, or other materials or property which result from or are used in such operations are situated..." § 34-32-103 (1.5).