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Mr. Gary Isaac <br />June 5, 2008 <br />Page 2 <br />3. CAM-Colorado has shown that mine inflow will occur during year six of the life-of-mine <br />operation. Further, the AVF Study states the following ..."Red Cliff expects to produce about 250 <br />gpm of water that will be discharged into the drainage below the mine portal." However, as <br />required by Rule 2.05.6(3) (b) (vi) the application still does not provide a description of the <br />location of the mine water discharge facility to be used within the permit area. Additionally the <br />application lacks a sufficient description and map prepared in accordance with 2.10 and <br />2.04.7(4)(a) of the locations of surface waters which will receive discharges from affected areas, <br />and any water which will receive discharges of water from the general area [2.04.5(1)], and in <br />accordance with 2.04.7(2)(a) the location of any water discharge into any surface body of water. <br />Thus, CAM-Colorado has not minimally addressed the requirements of 2.04.7 and 2.05.6(3). <br />4. Response accepted. This will be reviewed further during the adequacy review period. <br />Response accepted. CAM-Colorado has minimally addressed the requirements of <br />2.04.6(3)(a)(iii). There is still some question as to the origin of the roof and floor data and whether <br />the data as submitted is sufficient to fully meet the requirements of 2.04.6(3). The adequacy of the <br />data will be determined during the adequacy review process. <br />6. Surface water information required by Rule 2.04.7(2) includes the location of all surface water <br />bodies including springs. If appropriate, the Division may also require the seasonal variations in <br />water quality and quantity at spring locations within and adjacent to the permit area. CAM <br />indicates that a few springs exist but provides no other information. In CAM-Colorado's <br />response, our comment regarding a spring and seep survey is noted, but no data were provided. <br />Since no data whatsoever were provided, CAM-Colorado has failed to minimally address the <br />requirements of 2.04.7(2) Surface Water Information regarding springs. Because seasonal <br />variations in these water bodies may need to be identified, the timing of a spring and seep survey <br />and subsequent data collection could become time-critical. For this reason the Division believes <br />that this should be addressed now as a completeness issue rather than as an adequacy issue. For <br />the application to be deemed complete CAM will at a minimum be required to submit a spring and <br />seep survey of the permit area and adjacent areas and locate them on an appropriate map. <br />7. Baseline surface water data have been minimally addressed by CAM-Colorado. CAM has <br />indicated in their response that the missing data identified by the Division will be collected as part <br />of its continuing baseline data collection effort. The adequacy of the data will be determined <br />during the adequacy review process. <br />8. Response accepted. Based on our initial review, modification of the AVF Study will be necessary. <br />CAM will be requested to provide additional mapping and information for East Salt Creek from <br />the point of mine water discharge down to the Highline Canal. This will be accomplished through <br />the adequacy review process.