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Mr. Kent Gorham <br />May 13, 2011 <br />Page 2 <br />DRMS: Response partially accepted. The application remains deficient with regard to the <br />details describing the water rights owned or leased by the mine and the estimated consumptive <br />use. Page 2.04-33 discusses the replacement of bedrock well water due to mining. Page 2.05-59 <br />and 60 provides limited information regarding estimates of demand for water. The application <br />does not provide sufficient detail regarding the water rights available to the operation. <br />Information provided by the Division of Water Resources (DWR) indicates that the DWR <br />Division 2 office may be working with NECC regarding the administrative exchange of up to 250 <br />acre-ft per year from the City of Trinidad. The application provides no information regarding this <br />exchange or other details on other water sources available to the operation. Rule 2.04.7(2)(a) <br />specifically requires "the application shall also contain information pertaining to ownership and <br />uses of surface water bodies." This Rule would include that information for the mine operation <br />itself. Please find the letter from DWR attached (March 29, 2011). In particular, paragraphs two <br />and four of the DWR letter should be reviewed and those issues outlined and addressed in permit <br />text narrative and include other permitting materials, as necessary. The major areas that require <br />additional detail include: <br />• The estimated demand and the proposed water supply <br />• Plans for future mine dewatering and need for a permit <br />• Storage and use of pumped groundwater <br />• Augmentation and/or substitute supply plans for consumptive use <br />Please provide the additional, detailed information as permit text narrative as requested. <br />NECC Response: The estimated demand and water supply is included on page 2.05-60. When <br />processing 3 million raw tons per year the mine is expected to require 148 acre-ft annually. The <br />Operator has two water leases, Hill Ranch and City of Trinidad for a sum total of 430 acre-ft. <br />Rule 2.05 Operation and Reclamation Plan <br />4. DBMS: Please revise permit text narrative on page 2.05-3 that clearly states what mining <br />activities are proposed under TR-56 Reference to Map 3 is appropriate. Refer to our comments <br />in the General Discussion section of this letter. Permit text narrative on page 2.05-3 is not clear <br />what activities are proposed under TR-56 Portions of the revised text and text in Exhibit 24 <br />seem to indicate subsidence from retreat mining in areas where the Division understands that no <br />retreat mining will occur. It is critical that there is no ambiguity or confusion as to the location <br />of surface areas where subsidence is planned. Please review the submittal in its entirety with <br />regard to this issue. <br />NECCResponse: Map 3, Figure 19, and permit text narrative on pages 2.05-2, 3, and 3a have <br />been added. <br />DRMS: Response partially accepted. Please add a sentence to the end fifth paragraph on <br />page [2.05-3], suggested text as follows "No retreat mining resulting in subsidence is <br />planned in this panel." <br />NECC Response: Page 2.05-3 has been modified as requested. <br />DRMS: What additional surface and ground water monitoring is proposed for the mine plan <br />proposed under TR-56? <br />Agapito Associates, Inc.