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County, Colorado (April 20, 2007). OSMRE determined that approval of the Mining Plan <br />modification would extend the life of the King II mine by 10 years. At the time, OSMRE <br />determined that approval of the Mining Plan Modification would not require the preparation of <br />an environmental impact statement under NEPA, finding that the modification would have "no <br />significant impact" on the environment. See Exhibit 3, OSMRE, "Finding of No Significant <br />Impact for King II, Federal Coal Lease COC -62960 Mining Plan Decision Document" (Feb. 22, <br />2007). According to OSMRE, this finding of no significant impact ("FONSI") was based solely <br />on an environmental assessment ("EA") prepared by the BLM. <br />The EA prepared by the BLM was completed in 2001, six years prior to the 2007 Mining <br />Plan modification approval. See Exhibit 4, BLM, "Environmental Assessment, EA Number CO- <br />SJFO-00-102-EA, National King Coal, LLC Coal Lease Application East Alkali Tract, COC <br />62960" (2001). When this 17 -page EA was prepared, the BLM projected that production at the <br />King II mine would be "300K ton per year." EA at 4. <br />Since approval of the 2007 Mining Plan modification, GCC has steadily increased its <br />production at the King II mine. See Table below. After 2008, GCC has regularly produced more <br />than 300,000 tons annually and since 2011, the King II mine has regularly produced more than <br />600,000 tons per year. Since the 2007 Mining Plan approval, the State of Colorado approved an <br />increase in the maximum annual production from 0.61 to 0.8 million tons and in 2014, approved <br />a permit revision that increased the production rate from 0.8 to 1.3 million tons per year. This <br />represents a more than four -fold increase in the projected coal production assumed by the BLM <br />in 2001 and a more than two -fold increase in the coal production that OSMRE in 2007 projected <br />would occur at the mine. <br />Coal Production from King II. Data from Colorado Division of Reclamation Mining and <br />Safety, http://mining.state.co.us/Reports/Reports/Pages/Coal.aspx.1 <br />Year <br />Amount of Coal Produced (tons) <br />2007 <br />7,434 <br />2008 <br />155,666 <br />2009 <br />502,212 <br />2010 <br />523,413 <br />2011 <br />618,132 <br />2012 <br />639,003 <br />2013 <br />737,131 <br />2014 <br />970,790 <br />2015 <br />813,677 <br />2016(projected) <br />768,136 <br />In spite of these production increases, no additional Mining Plan modifications have been <br />approved or even proposed by OSMRE or the Secretary of the Interior. Further, no additional <br />environmental analysis of the impacts of operating the King II mine has been undertaken <br />pursuant to NEPA since the BLM's 2001 EA was prepared. <br />1 Projected 2016 production amount based on reported production data for first quarter of 2016 reported to Mine <br />Safety and Health Administration, httl2:Hminin2.state.co.us/Rel2orts/Rel2orts/Pages/Coat.asl2x. <br />5 <br />