Laserfiche WebLink
2. There has been no further federal review. <br />The 2001 Environmental Assessment is a sketchy basis for approval of a project this size <br />with this scale of impacts. It was, frankly, a very weak effort. <br />But the deficiencies of this analysis are magnified by the fact that there has been no <br />subsequent federal permitting or analysis in the last fourteen years, while the mine <br />production level has increased over 400%.2 <br />The Division Has Been Headed Down the Wrong Path <br />DRMS has been facilitating this expansion and helping to keep it "under the radar' of <br />public scrutiny by two incorrect approaches that really need to be reversed <br />immediately. <br />The changes in the permit have been divided up piecemeal and considered <br />separately; and <br />They have been improperly treated as Technical Revisions rather than Permit <br />Amendments, thus allowing them to proceed without the public being aware, <br />and without adequate public participation. <br />TR 23, TR 24, TR 25 and TR 26 are all part of the same process of expansion; there is no <br />justification for treating them separately. <br />There is also no justification for treating these matters as Technical Revisions, whether <br />considered separately or together. The only reason for doing that is to truncate and <br />avoid public awareness and public participation; the company knows the depth of public <br />feeling and wants to "fly under the radar." This is not an approach that the Division <br />should facilitate. <br />TR 23 allows an expansion in the production level from 800,000 tons per year to <br />1,300,000, when the 800,000 ton level was already causing unacceptable impacts that <br />were being regulated at no level of government, and the only analysis of impacts was <br />based upon a 300,000 ton production. Yet somehow TR 23 was supposed to be a <br />"technical revision." <br />TR 24 would add something like 87.3 acres to the permit area. Somehow the Division <br />made a determination under C.R.S. § 2.08.4(2)(b) and (c) that adding 87.3 acres to the <br />existing permit area was an "incidental boundary revision." <br />2 There is another EA in the works, but no date or deadline for that process. <br />