2011-12-01_APPLICATION CORRESPONDENCE - C2010089 (2)

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Birds Mexican spotted owl Threatened Threatened Yellow - billed cuckoo Candidate Candidate Fish Bonytail Endangered Endangered Colorado pikeminnow Endangered Threatened Humpback chub Endangered Threatened Razorback sucker Endangered Endangered Plants Clay - loving wild buckwheat Endangered No Plants Listed Colorado hookless cactus Threatened No Plants Listed It does not appear that Plants have been considered in the PAP. In addition, no depletion analysis is presented (this may be able to be derived from the analyses performed by BBA and WRS) to support WFC's assertion that there will be no depletions, and thus no harm to the Endangered fish, on the San Miguel River caused by this project. Please provide a water depletion analysis for the proposed New Horizon North Mine. The water depletion analysis will be forwarded to the OSM and USFWS and is required to make a finding for the threatened and endangered fish species in the Colorado River. Response — The water depletion information from the BBA/WSI report pertinent to NHN Mine was provided to DRMS on October 5, 2011. It is also being submitted with this letter to be included in the PAP as Appendix 2.04.11 -2. Please be aware that this study represents a "worst case scenario" as it does not include any additional contributions to the hydrological balance to the surface water system which will result as mine pit dewatering of the groundwater occurs in advance and during the mining operations. WFC believes that the dewatering of the mine pits will result in an overall net increase in surface water to the Tuttle Draw and Coal Canyon drainages, as well as the San Miguel River. The DRMS comment that the PAP has not considered federally listed "plants have been considered in the PAP" is incorrect. Clay- loving wild buckwheat is specifically addressed on pages 24, 25 and 27 of Section 2.04.10 of the PAP. At the time that the original text for Section 2.04.10 was prepared, Colorado hookless cactus did not exist as a recognized species and did not come into existence until the