2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response 71 025 Julia Dengel Individuals I understand that the amount of trucks will not increase from what is currently permitted See response Line 26. and I am grateful that the county limited the number.However,I want to point out that 240 truck trips is a huge amount of traffic,especially for this rural area.Every day I pass multiple coal trucks as I commute to and from work in Farmington.The road narrows in me places(particularly a bridge south of Long Hollow reservoir)and it can be harrowing to negotiate the roads with large,fast-moving coal trucks a constant feature.I continue to be concerned about safety on public roads when a private company is such a large contributor of traTfc. 72 025 Julia Dengel Individuals am concerned about the impacts on wildlife,including mammals like elk,deer,mountain See response Line 18. The 2017 Lease Modification EA,included golden eagles,peregrine falcons,and lion,bear,bobcat,fox as-11 as the many bird species that use the area.You mention bald migratory birds in its analysis.That EA has been incorporated by reference into this EA. eagles and kestrels,antl I woultl like to atltl go' eagles(frequent sighting reported nearby)and a ne falcons as well as scones of mi rato birds. 73 025 Julia Dengel Individuals My understanding is that coal prices are in free fall right now,and this is not a good time to Comment noted.This comment is beyond the scope and purpose and need for this EA, be a coal sellenlessw.If the ELM decides to go ahead with this lease regardless of the above concerns,I urge the ELM to delay until such time that the price of coal is at a historic high rather than at the current time Dive low r 74 025 Julia Dengel Individuals While all local residents,myself Inclutled,value havving jobs in the area,I am concerned that Comment noted.GCC's administrative choices for salaried vs.hourly paid employees are beyond the scope GCC has o ly 12 salaried employees out of 86 workers,and the rest are hourly workers. of the EA. Jobs are a real value,but the quality ofjobs and the terms of employment are equally important antl 1 woultl have a better New of the company if it made a bigger commitment to its workers b e ntlin thetool of salaried em e 75 025 Julia Individuals Also,after a recent severe accident at the mine,I am concerned about worker safety with As described in the EA Section 3.3,information on health and safety presented in previous EAs has not Dengel+[@Classification]O66[ further expansion. changed and is still applicable.Additionally,as the Proposed Action under review in this document is a @[Organization/Agency Name]] continuation of the previous 2017 action,impacts previously described would be similar over an extended eriod of time. 76 025 Julia Dengel Individuals I urge the federal government to address all tribal concerns as it relates to this proposed BLM and OSMRE will continue government to government consultation with I terested tribes.The agencies project. will work to resolve any tribal concerns identified in the future.No issues were identified by the Tribes during the NEPA process. 77 026 Robert Burnham Individuals In light of the FONSI, su wt issuin the r uestetl lease. Comment note 78 027 Wild Earth Guardians Organizations/ OSMRE's Involvement is Premature.OSMRE has no role in the current decision-making OSMRE's involvement as a joint lead agency is in conformance with CEO regulations and guidelines,and Non-profits process other than to provide information antl expertise to guide BLM's review of the with Departmental and agency NEPA regulations and policies.Those regulations,policies and guidelines all proposed federal coal lease,which is the role that cooperating agencies play under CFR. uraga agencies to coordinate their NEPA actions at the earliest possible stages,and to reduce paperwork antl NEPA process delays.By coordinating and combining their NEPA analyses,the agencies save staff time and dollars when compared to each agency preparing its own document.CEO regulations at Part 1508.25(a)(1)indicate that"connected actions",meaning they are closely related,should be analyzed in the same NEPA document.That CEO regulation goes onto define"connected actions"as those that"... nnot or will not proceed unless other actions are taken previously or simultaneously."A BLM decision to lease federal coal for development clearly immediately precedes OSMRE's action to make a tlecision about approval of a mining plan or its modification.BLM's NEPA Handbook(H-1790-1)states that"...Expanding the scope of a NEPA analysis to consider connected and cumulative actions of all cooperating agencies into a single tlocument improves overall interagency cowtlination."Further,the handbook indicates that agencies working cooperatively helps the public to participate effectively and efficiently.By combining NEPA efforts between agencies the public can better understand the entire scope of a proposal,rather than being presented with a piece of it earlier and another piece later.This cooperation also ensures that the NEPA tlocum am specifcally addresses the comprehensive action that must be considered and disclosed to the Public beiwe the make their decisions. 79 027 Wild Earth Guardians Organizations/ An Environmental Impact Statement is required.We object to the BLM's proposal to rely on See response line 85ncGuitlance in the Departmental Manual at 516 DM 11.8(B)and section 7.2 of the BUM Non-profits an Environmental Assessment("EA")for the proposed lease application.The proposed NEPA Handbook H-1791-1 state that certain specified actions"...normally require the preparation of an lease is clearly a class of action that normally requires the preparation of an environmental EIS."However,the Departmental guidance goes on to state at 11.8(B)and(C)that"If potentially significant impact statement("EIS").Furthermore,given the potentially significant impacts of the impacts are not anticipated for these actions,an EA will be at The BLM NEPA Handbook at section proposed King 11 mine expansion,an EIS is all the more warranted. 7.2 refers tlirectly to section 11.8(B)and(C).Both the Departmental Manual and ELM NEPA Handbook therefore give the ELM the decision space to determine if an EIS is needed even if the proposed action is e of the specified actions that"normally"requires preparation of an EIS.The proposed action is an extension of an existing underground mining operation that includes a maximum of 20 acres of surface disturbance over the life of the mine.Up tc 10 of the 20 acres would be disturbed and reclaimed in the first year during construction of underground access to the new lease if it is issued to GCCE by BUM.Based on the analysis in Chapter 3 of the EA and Chapter 2 of the TRR of potential impacts on environmental rescurc es,the BLM has tleterm ined that the potential impacts do not nse to the level of significant that would I require aration of an EIS. 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