2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response 95 027 Wild Earth Guardians Organizations/ OSMRE and SLIM must fully analyze and assess direct,intlirect,and cumulative impacts to Section 2.2 of the TRR and Section 3.4.1 present a comprehensive analysis of the potential air quality Non-profits air quality,inclutling impactsto air quality in the context of all National Ambient Air Quality impacts of the Proposed Action,including all NAAQS,PSO increments,and VOCs.No blasting is included Standards('NAAQS"),prevention of significant deterioration("PSD")increments for Class I in the Proposed Action and therefore the project would not produce nitrogen dioxide or any other pollutants and 11 areas,and visibility impacts to Class I areas.We are particularly concerned over the from that potential source.The Project Area is in a Class 11 area as codified in the Colorado State PSD impacts of the mining to NAAQS for ozone,particulate matter,and nitrogen dioxide(which permitting rules.Mesa Verde National Park is described in Section 2.2.1.2 Regulatory Requirements of the is produced during blasting).The EA does not present such an analysis of air quality TRR as the closest Class I area at 14 miles may.The regional area associated with the Proposed Action, impacts.We are especially concerned over the air quality impacts to nearby Mesa Verde which has included operation of the King 11 Mine for the last 7 years,meets all applicable air quality National Park,which is a Class I area untler the Clean Air Act and a cultural gem of the standards and is considered in attainment.NO impacts to Class I areas are expected.Section 2.4.6 of the American Southwest.OSMRE and BUM must ensure that air quality is not unduly degraded EA and Section 3.1.2 of the Lease Modification EA(BLM 2017)explain the reasons why the lung II mine is in this Park and also ensure that is safeguarding all air quality-related values in Mesa naturally low in methane and therefore the potential impacts of methane emissions from the mine.In addition Verde.We are further concerned that the impacts of methane emissions and related volatile the Lease Modification EA(BLM 2017)in Section 3.1 also comprehensively analyzes the potential impacts to organic compound('VOC")emissions from mine ventilation operations have never been air quality.The Lease Modification EA is incorporated by reference in this EA. analyzed and assessed.VOCs are key ozone-forming pollutants and are listed as regulated pollutants at 40 C.F.R.50.100(s).VOCs include gases such as propane and acetylene, both of which the U.S.Mine Safety and Health Administration requires mining companies to vent in order to maintain safety.See 30 C.F.R.§75.321(b).Although the State of Colorado requested information regarding VOC emissions from King 11,the state never followed through with that request.Thus,it is appropriate for OSMRE and BLM to ensure this information is provided in order to guide the agencies'analysis and assessment of air quality impacts.The preliminary EA fails to address this issue,rendering any finding of no significant impact unsu ad. 96 027 Wild Earth Guardians Organizations/ OSMRE and BLM must specifcally address all emissions sources,particularly those that See response line 95 Non-profits not explicitly permitted by the State of Colorado(including blasting emissions).The agencies must quantify emissions from the mine to ensure an accurate and adequate nalysis antl assessment of air quality impacts.The current EA does not present such an anal sis antl therefore is hawed under NEPA. 97 027 Wild Earth Guardians Organizations/ OSMRE and BLM must fully analyze and assess the impacts of mine waste disposal and See response line 95 Non-profits other related actions occurring at the nearby King I coal mine.GCC currently disposes of in me waste at King 1,although it has never formally been approved by the State of Colorado.The impacts of such disposal,particularly to water quality,soils,and vegetation, must be fully analyzed and assessed in an EIS.The preliminary EA acknowledges that waste disposal at the King I mine will occur as the proposed coal lease is mined.However, the EA fails to disclose the of 02direct,indirect,and cumulative impacts of waste disposal rations at the Ion mine antl therefore is tlefcient under NEPA. 98 027 Wild Earth Guardians Organizations/ OSMRE antl BLM must fully analyze antl assess the impacts of coal transport from the King This EA incorporates by reference the analysis of coal transport in the 2017 EA(Section 3.10)which Non-profits 11 mine,inclutling the impacts of trucking coal from the mine and the impacts of hauling the includas much of this information.As the current Proposed Action is a continuation of the current coal coal by rail to cement processing facilities.Such an analysis must fully analyze and assess transportation methods with no increase over what was previously analyzed,that information is still valid. the air pollution impacts of transport,the impacts associated with spills of coal from trucks Additional information and analysis of the environmental impacts of hauling coal,both through rail and truck, antl trains,the water quality impacts related to road degradation from heavy traffic,and the is presented in the TRR,Section 2.2 and 2.3.Additionally,GCC has entered into Road Improvements safety impacts associated with transport.Such an analysis and assessment must disclose Agreement with La Plata County to improve the quality of the roads to prevent possible future impacts. impacts related to truck hauling from the mine to all destinations,including the rail loading facility in Gallup.It also must address the impacts related to rail hauling of coal from the Gallup facility.The preliminary EA contains no such analysis or assessment of reasonably foreseeable coal transport impacts connected to coal production at the King 11 mine. Although the EA acknowledges that coal is trucked from the mine and much of it shipped by rail from a terminal in Gallup,the EA presents no analysis or assessment ofthe air pollution impacts of transport,the impacts associated with spills of coal from trucks and trains,the water quality impacts related to road degradation from heavy traffic,and the safety impacts ociated with trans ort. B-10