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• • iii iiiiiiiiiiiiiiii Colorado Yampa Coal Company I 29588 Routt County Road #27, Oak Creek, CO 80467 • (303) 879-3800 November 1, 1985f Mr. Steve Parsons Office of Surface Mining Brooks Towers 1020 15th Street Denver, Colorado 80202 R~C~~VED Nay~B ~ Re: Wi nes in Dear Mr. Parsons: cMw; ~~a~~~~M ~fOUI~ Enclosed you will find an analysis of projected streamflow depletion of Colorado Yampa Coal Company's (CYCC) surface coal mines located in the Yampa River drainage of the Upper Colorado River Basin (UCRB). This submittal is being made to comply with the Windy Gap Policy of the U.S. Fish and Wildlife Service (USFWS) as it relates to the preservation of habitat for USFWS listed threatened and endangered species of the UCRB. This submittal was prepared according to the examples you sent and gui- dance we received from you in several conversations over the telephone. As we explained to you, mining activities in this area have been planned for almost a year and a half, and if approval to commence topsoil removal operations is not received within the next few weeks, the entire lease tract might have to be bypassed. Also, please note that due to our time constraints and in hopes of expediting the approval of this document, we have taken a "worst case" sce- nario. We are taking this approach not because we believe the assumptions given us were reasonable or applicable to our mine. We believe that suffi- cient site specific data is available from our mine that documents that aug- mentation rather than depletion will be encountered as a result of mining. However, due to extensive amount of documentation that would be required to support this position and the shortage of time, we feel that if the coal is going to be mined we have no alternative but to follow your current guide- lines. Colorado Yampa Coal Company therefore respectively submits this evalu- ation with reservations and under protest because we do not feel that the guidelines given us represent actual conditions in our mine area. It is our belief, based upon data which CYCC, the USDA Agricultural Research Service and USGS `Rater Resources Division has collected, that the impacts of mining re- sults in a net increase in surface water flow instead of depletion as pro- jected herein. Separate streamflow depletion analyses have been conducted for (1) all mining activity authorized by CYCC Permit 79-177 at Mines 1, 2 and F_c:<man Park, and (2) mining associated only with Lease 26914, which is a newly leased 30 acre tract. As of this writing, CYCC is unsure if we are required to evaluate streamflow depletions for the entire mine or for only the new 30 acre lease tract. Therefore, we have followed your recommendation to submit both