2020-10-27_PERMIT FILE - C1981035 (23)

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ENVIRONMENTAL ASSESSMENT in moving supplies and workers between the existing mine and the Project Area that would increase operating costs and could pose a threat to worker safety. The overall cost of the switchback road sub-option is also significant due to the combined costs of construction, maintenance, and permitting.The road would require many annual labor hours and special equipment to maintain the road surface and drainages, pull equipment up the grades, plow snow, and mitigate dust.Also,the cost and time of gaining LPC permits to allow for the road to be constructed would substantially increase overall costs and delays to the Project. Considering the combined costs of the switchback road option, along with the costs of a new enclosed conveyor belt system, two new mine portals, and a new ventilation system,this alternative would be economically infeasible. From an environmental effect standpoint, the switchback road sub-option would present additional substantial adverse environmental effects when compared to the Proposed Action. Constructing the two new mine portals and the switchback roads would require large cuts and fills on both sides of the Gulch. Both the switchback roads and a road across the bottom of the Gulch would result in long term surface disturbance. The amount of surface impact for the switchback road sub-option is estimated to be 50 percent larger than the disturbance would be for the Proposed Action, and the impacts would be long term rather than temporary as they would be under the Proposed Action. Further, the switchback roads would be highly visible features, affecting the visual resources of the area. Lastly,the noise of equipment traffic operating frequently on the roads in the Gulch would be an adverse effect not presented by the Proposed Action. In addition to being economically infeasible,this alternative would result in substantially greater adverse environmental impacts than the Proposed Action, including greater impacts to miner and public health and safety, and therefore was eliminated from further consideration. 2.4.3 Central Mine Area Surface Access Alternative A third alternative LBA access site that was considered was to develop a surface access from the west central part of the existing mine directly north across the Gulch into the LBA. However, in this location the coal seam is located approximately 100 ft above the floor of the Gulch. This alternative would require construction of the same new facilities as described for the alternative above(Section 2.4.2). For the same reasons as described for the alternative above(Section 2.4.2), in addition to being economically infeasible, this alternative would result in substantially greater adverse environmental impacts than the Proposed Action, including greater impacts to miner and public health and safety, and therefore was eliminated from further consideration. 2.4.4 Southern Mine Area Surface Access Alternative The fourth LBA access alternative that was considered but eliminated from analysis was construction of a road across the Gulch on the surface at the southwestern end of the OSMRE permit area in the same location as the Proposed Action. The road would be constructed from the existing mine workings to the northwest across the Gulch and into the LBA reserves.This alternative would require construction of new mine portals on both sides of the Gulch, a permanent access road across the Gulch, a new covered conveyor system, a new ventilation system for the mining in the Project Area, and new surface electrical Dunn Ranch Area Coal Lease by Application COC-78825 and Mine Plan Modification EA 2-12