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a <br />Richard D. Lamm <br />Governor <br />DEPARTMENT OF NATURAL RESOURCES <br />David H. Getches, Executive Director <br />MINED LAND RECLAMATION DIVISION <br />DAVID C. SHELTON, Director <br />September 5, 1986 <br />Mr. Dennis Conn <br />Director Permitting & <br />Environmental Compliance <br />West Elk Coal Company <br />P.O. Box 591 <br />Somerset, Colorado 81434 <br />III IIIIII IIIIIII III <br />999 <br />Re: U. S. Forest Service Review Comments for Mt, Gunnison No. 1 Mine Permit <br />Renewal, File No. C-80-007 <br />Dear Mr. Conn: <br />Recently our office received correspondence from the U.S. Forest Service, <br />Paonia Ranger District, regarding the permit renewal for the Mt. Gunnison No. <br />1 Mine. In particular, District Ranger, Steven Posey had concern for <br />protection of stock water resources within the West Elk Coal Company lease <br />area. The USFS has included, in its comment letter, maps and a computer <br />listing of springs and ponds which they have inventoried above the proposed <br />permit area. I have enclosed copies of all correspondence received. <br />The U. S. Forest Service is concerned that the springs which provide grazing <br />water to the livestock on USFS grazing leases be protected from damage due to <br />subsidence. The permit, as amended, includes a combined traditional survey <br />and aerial photographic subsidence monitoring program, which we have judged to <br />be adequate to monitor the mechanical response to subsidence. The purpose of <br />this plan is to verify those mechanical predictions included within the WECC's <br />application, which project maximum vertical subsidence and the associated <br />angle of draw. Further, the application contains a hydrologic monitoring <br />plan, which includes a spring monitoring component. Our review of the WECC <br />spring monitoring plan for both 5-year and life-of-mine permit areas found the <br />plan to be adequate to protect the springs inventoried. <br />Since the question raised over protection of stock water resources is valid, <br />the Division must require West Elk Coal Company to verify that all of the USFS <br />inventoried springs are included within their hydrologic monitoring plan, <br />WECC should either obtain agreement from the USFS to monitor only selected <br />springs from the list of all inventoried springs or should amend their <br />monitoring plan to include any overlooked springs. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />