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Submission# Organization/Agency Name Commenter Type Comment Comment Response
<br /> 65 025 Julia Dengel Individuals I am disturbed that this project is being fast-tracked through the review process,and believe As part of the analysis for the EA,a determination was made that the alternatives are in conformance with
<br /> that a full environmental impact statement is a necessary minimum given the size of the the TRFO Approved RMP(ARMP)and ROD(BLM and USFS 2013).Please refer to Section 1.5 of the EA.
<br /> proposed expansion antl given that it follows immediately on the heels of a previously The EA tiers to the ARMP.The TRFO ARMP determined that a coal unsuitability study previously completed
<br /> approved expansion.This latter point is of grave concern to me.Why tlitl GCC fail to by BLM(BLM 1985)is still valid.That study identified 46,000 acres of the Durango KRCRA with an
<br /> request this amount of acreage in their last expansion request?Not long ago they received estimated coal resenre of 1.5 billion tons that were acceptable for further consideration for coal leasing and
<br /> expansion approval.It concerns me that GCC is upending in increments and thereby which includes the GCCE mine area and
<br /> the Dunn Ranch Area LEA.Further,Future GCC lease expansion
<br /> Vic'ng a'
<br /> environmental review of their planned operations.I woultl like to see a stutly and other area coal development was disclosed as reasonably foreseeable to occur in the 2017 EA and is
<br /> done on the impacts of develIping the full supply of 1.5 billion tons contemplated in the EA, described in Section 4.2 Reasonably Foreseeable Future Actions of that EA as follows:"It is reasonable to
<br /> rather than incremental approval that relies on past studies and does not take into account expect that GCC will again propose inodifcation of their federal coal lease and/or will apply for a lease by
<br /> cumulative
<br /> impacts.In fact,I would urge the BLM and OSMRE not to lease more coal until application to extend the life of the mine further into to the future than can be done via a traditional lease
<br /> you have completed a full study of the cumulative impacts of the full amount of coal the modifcation."and"Based on the unsuitability ass ments(BLM 1985;SJNF 1983),46,000 acres are
<br /> BLM has identified as available for development. iidentifed as acceptable for further consideration four coal leasing within the TRFO,with an estimated reserve
<br /> 0f 1.5 billion tons."Past,present and reasonably foreseeable developments in the region,including of coal
<br /> as presented in Section 4.3 Cumulative Impacts of the 2017 EA which is incorporated by
<br /> reference in this EA.
<br /> 66 025 Julia Dengel Individuals The EA contemplates up to 17 million tons of coal being mined including the currently Section 2.2.6.2 of the TRR antl section 3.4.1.1 of the EA provitle can prehensive discussions of Greenhouse
<br /> permitted coal leases,out of a total of 1.5 billion potential tons of coal in the area.The EA Gases(GHGs),sources of GHGs including the proposed action,climate change and the potential impacts of
<br /> estimates that over the course of the life of the proposed lease approximately 450.6 million climate change.The many interrelated natural systems and associated feedback mechanisms that contribute
<br /> tons of CO2e could be released into the atmosphere.While the EA indicates this is not a to climate variability over the entirety of the Earth makes analysis of this issue exceptionally complex.The
<br /> significant impact,I disagree.I am very concerned about the effects of climate change on agencies tlitl calculate that over the projected 22 year life of the mine,450.6 mt of CO2e emissions would be
<br /> (antl,water,air,and weather patterns,and
<br /> believe it is a grave mistake to continue any coal produced cumulatively from all sources related to the proposed action and the produced coal's uses
<br /> leasing,particularly fast-tracked leasing without a full environmental impact statement, dmnstream including direct,indirect and downstream coal conbustion.These emissions are then compared
<br /> when the world is being negatively impacted by the already high levels of human- in the TRR(Section 2.2.6.2)and the EA(Section 3.4.1.1)to similar local,state,national and global GHG
<br /> contributed greenhouse gases in the atmosphere. Zons"Zoes.The cumulative emissions from the proposed action represent approximately 0.09°6 of
<br /> the mean face value(500 GtCO2)of the carbon budget.The agencies have determined that the proposed
<br /> action is not a significant contributor to CO2e emissions over the life of the mine.The commenter provides
<br /> ne
<br /> w information or data on the potential impacts of the proposed action on climate change that would
<br /> require
<br /> further analysis in this EA.
<br /> 67 025 Julia Dengel Individuals The Mineral Leasing Act of 1920 was passed in a time when climate change was not See response line#3 SWhile the MLA was enacted in 1920,it has been amended numerous times over the
<br /> understood to be an imminent threat t0 the stability of our weather systems.Nearly 100 last 99 years and is still in effect.All analyses of potential environmental impacts performed in this EA,
<br /> years Inter we need to make decisions based on current science.It no longer makes any inclutling those analyses related to air quality antl climate change,use the best available,current science
<br /> me to be leasing coal from federal lands,which,according to your document,is a and data.The EA evaluates the direct,indirect and cumulative impacts of the mining and use of the coal in
<br /> significant source of burnt coal in the US. the context of the latest science on climate change(refer to section 2.2.6.2 of the TRR and Section 3.4.1.1 of
<br /> the EA).As an example,in 2015,BLM in Colorado commissioned the development of the Colorado Air
<br /> Resources Management Modeling Study(CARMMS)to model the future project potential air quality impacts
<br /> of reasonably foreseeable oil and gas development and coal mine production of federal coal.The CARMMS
<br /> data was later updated in 2017 so the results would be as current as possible.The conclusions reached in
<br /> this EA about the nature and level of the potential impacts ofthe proposed action on climate change are
<br /> based on the best contemporary science on climate change as described in detail in section 2.2.6.2 of the
<br /> TRR.
<br /> 68 025 Julia Dengel Individuals Being a layperson reading a technical tlocument, am unclear if the EA estimates on The EA outlines particulate emissions from both direct(from the mine extraction)and intlirect(combustion of
<br /> particulate matter inclutled air quality measurements at all the cement plants where the coal coal at the cement plants etc.)sources.All emission points at the cement plants(kilns etc.)are factored into
<br /> is burned,but any environmental assessment shoultl inclutle such impacts,including the emissions tliscussed in the EA.Please see Tables 3.3 antl 3.4 of the EA(Section 3.4.1.2).Also,the TRR
<br /> articulate emissions at the kilns. ovitles more tletail r artlin all emissions Section 2.2.2.
<br /> 69 025 Julia Dengel Individuals In ad-d tion,I have concerns about how the proposed project will affect water in other ways. Alluvial monitoring wells are currently installed upgradient and downgradient of the proposed low cover
<br /> These inclutle the impact on Alkali Gulch and downstream from the Gulch crossing.I notice crowing to monitor alluvial groundwater quality and quantity before,during,and after construction.Federal
<br /> in the EA that the trenches dug for the crossing are planned to extend 40 feet into the regulation 30 CFR 817.41(j)requires the permittee to promptly replace any drinking,domestic or residential
<br /> grountl. see from the EA that the groundwater is 3640 feet deep.The EA says the water supply that is diminished or interrupted by underground mining activities.The alluvial monitoring wells
<br /> 9r.nd water would not be affected but the deep trenches,but if I am reading the document in Alkali Gulch will serve to monitor groundwater quantity and quality to protect drinking water supply.
<br /> right,this appears to be an error.If ground water is at 3640 foot depth and the trenches
<br /> extend to that depth,that woultl mean the trenches woultl reach the groundwater level.
<br /> This is deeply concerning.What will the impacts be if the trenches reach groundwater
<br /> levels?
<br /> 70 025 Julia Dengel Individuals am also concerned about the waste pile from the mine,and the impact of runoff through The EA describes in Section 3.3 that public health and safety,which includes information on and analysis of
<br /> the waste pile.I am concerned also about the topsoil and fill soil piles should a large runoff the impacts of mine waste,was eliminated from detailed analysis in this EA because the resource was
<br /> vent occur during construction of the crossing. adequately analyzed in BLM and OSMRE(2017)(Section 1.5).This EA incorporates BLM and OSMRE
<br /> (2017)by reference.Please refer to Section 3.2.1 of BLM and OSMRE(2017).In addition,Section 2.2.3 of
<br /> this EA states that:"All mine refuse is contained within a constructed waste bank.Historical drainage in this
<br /> ea has been modified and engineered to facilitate separation between the refuse pile materials and
<br /> s of water."Section 3.4.2.2 of the EA describes that storm water would be"temporarily diverted
<br /> around
<br /> the construction area and then back into Alkali Gulch."The topsoil and fill soil piles woultl be included
<br /> as part of the"construction area".The EA further states that:"Impacts to surface water in The Gulch would
<br /> be minor to moderate,short-term,and local."
<br /> B-5
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