2018-06-01_REVISION - C1980007 (2)

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• Request that DRMS and Arch Coal permit a site visit by Objectors to gather information relevant to the informal conference; and • Object to OSMRE's review and proposed approval of any proposed mining plan modification related to PR -15 on the basis that such review and approval would be contrary to the Surface Mining Control and Reclamation Act ("SMCRA") and other applicable federal laws and regulations. Below, we detail our concerns and provide justification for our objections and requests. Background On March 23, Arch Coal submitted to DRMS an application for a Permit Revision for the West Elk mine, proposing to add two recently approved federal coal lease modification to the mine's permit area. This Lease Modifications area consists of 1,520 acres that are part of the Grand Mesa, Uncompahgre and Gunnison National Forest, including lands that are part of the Sunset Roadless Area. The permit revision would also add additional adjacent private land, sanctioning access to an additional 1,100 acres of both private and publicly -owned coal. Approving this permit revision is not in the public interest because it will destroy and degrade Roadless forest directly adjacent to the West Elk Wilderness, because it will condone illegal air pollution associated with Arch Coal's surface coal mining activities, and because it would allow Arch Coal to continue to vent massive amounts of methane gas with no consideration of viable alternatives for address these emissions. We are first concerned that the permit revision violates Mined Land Reclamation Board ("MLRB") regulations that require mining operations to "minimize disturbances and adverse impacts of [mine] operations on fish, wildlife, and related environmental values." See MLRB Rule 4.18(1). Specifically, we are concerned that Arch Coal plans on building unnecessary roads within the Roadless area to access the additional acreage that this permit would allow. This appears to violate MLRB Rule 4.18(5)(a), which requires that roads be located and operated so as to avoid or minimize impacts to fish and wildlife species. Moreover, the revision fails to limit the climate impacts of methane pollution, also raising concerns that Arch Coal is failing to use the "best technology currently available" to minimize disturbances and adverse impacts to fish, wildlife, and related environmental values consistent with MLRB Rule 4.18(1). Further, the proposed permit would fail to ensure that Arch Coal will operate the West Elk mine in compliance with State and Federal air quality laws and regulations consistent with MLRB Rule 4.17. Finally, the proposed permit would fail to ensure that Arch Coal achieves effective contemporaneous reclamation of its surface coal mining operations consistent with MLRB Rule 4.13. 2