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2016-12-13_REVISION - C1996083 (125)
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2016-12-13_REVISION - C1996083 (125)
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Last modified
1/13/2017 7:05:44 AM
Creation date
1/13/2017 6:52:18 AM
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Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
12/13/2016
Doc Name
Public Comment and Request for Public Hearing
From
Jeremy Nichols Wild Earth Guardians
To
DRMS
Type & Sequence
TR110
Email Name
JDM
MPB
JRS
Media Type
D
Archive
No
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Ginny Brannon, Director <br />Colorado Division of Reclamation Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Ginny.brannon&state.co.us <br />Re: Objection to Bowie No. 2 Coal Mine (Permit No. C-1996-083), Technical Revision <br />No. 110 (TR -110), Installation of unprecedented coal gasification plant within the <br />permit area <br />Dear Director Brannon: <br />We, the undersigned, are writing to convey our objections to the Colorado Division of <br />Reclamation Mining and Safety's ("DRMS's") proposal to approve Technical Revision No. 110 <br />to the mine permit for the Bowie No. 2 coal mine, Permit No. C-1996-083. Below, we also <br />present a request for a public hearing, pursuant to the November 30, 2016 notice published in the <br />Delta County Independent. <br />For the following reasons, there is no basis for DRMS to approve the revision as <br />proposed by Bowie Resources, LLC and we object to DRMS's proposed approval. Further, <br />because the proposal would represent a significant change to Bowie's operations, the current <br />proposal meets the definition of a Permit Revision, which must undergo more robust review and <br />public involvement. <br />Bowie's proposal is to construct a coal gasification facility on its Bowie No. 2 coal mine <br />site. As stated in the company's application, the facility, known as a "DAXIOM Plant," "will be <br />used to convert coal mine waste to synthetic gas which is then used either to generate electrical <br />power or diesel/fuel oil." In essence, Bowie is proposing to construct what amounts to an oil <br />refinery and possibly a new power plant. This facility is both unprecedented (we are unaware <br />that anything like it has been approved anywhere in the state in the last few decades) and poorly <br />described and understood (the "DAXIOM" process appears to be in use nowhere in the world; <br />not a trace of it could be found on the internet). It would represent a major new and intrusive <br />industrial development in Colorado's North Fork Valley. Such a facility would represent a <br />dramatic change within Bowie's permit boundary, potentially turning a coal mining operation <br />into a hydrocarbon refinery facility. Such an operation could pose significant impacts to fish and <br />wildlife, water quality, air quality, climate, the natural integrity of the region, and the socio- <br />economic fabric of the North Fork Valley. <br />Copied on this letter are the U.S. Office of Surface Mining Reclamation and Enforcement <br />("OSMRE"), Bureau of Land Management (`BLM"), the U.S. Forest Service ("USFS"), <br />Colorado Air Pollution Control Division ("APCD"), the Colorado Water Quality Control <br />Division, the Colorado Hazardous Materials and Waste Division, and the Environmental <br />Protection Agency ("EPA"). As it stands, the proposed permit revision has significant <br />implications for air quality, water quality, and waste management, and potentially may affect <br />BLM and Forest Service lands. We urge that DRMS not permit such an unprecedented, <br />
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