2020-10-27_PERMIT FILE - C1981035 ‎(22)‎

• Permit No: C1981035
• IBM Index Class Name: Permit File
• Doc Date: 10/27/2020
• Section_Exhibit Name: KII Appendix 16 Dunn Ranch LBA Technical Resources Report
• Media Type: D
• Archive: No

2.2 Air and Climate Resources
2.2.1 Affected Environment
2.2.1.1 Airshed for Analysis
The affected environment for the air quality analysis includes La Plata and Montezuma counties,although
most direct air quality impacts would be limited to the vicinity of the mine itself(BLM and OSMRE 2017,
Map A-5). Indirect effects associated with coal transport and combustion occur at numerous locations.
Most of the coal produced (approximately 83 percent) is transported by truck to a rail terminal in Gallup,
New Mexico. Approximately 1,067,040 tons per year (tpy) can be delivered to markets in the
southwestern U.S. via the Gallup rail hub. Of the total, approximately 181,000 tpy are delivered by truck
to two GCC-owned and operated cement plants in Pueblo, Colorado (105,000 tpy) and in Tijeras, New
Mexico (76,000 tpy) where the coal is used as a fuel source in the cement manufacturing process. Small
coal volumes are also sold and delivered by truck to the Durango & Silverton Narrow Gauge Railroad
(3,600 tpy),the Cumbres and Toltec Scenic Railroad in Chama, New Mexico (1,500 tpy), and locally(7,000
tpy)for home heating.The remaining approximately 880,940 tons would be delivered by rail from the rail
terminal in Gallup, New Mexico to GCC-owned cement plants in northern Mexico (240,000 tpy) and to
variable cement facilities in Arizona and Texas. It is unknown as to which cement plant(s) King II coal may
potentially be sent within Arizona and Texas,or even to which more general geographic areas within those
states.This is because of two reasons: 1.)the facilities in those states that are potential purchasers of King
II coal are not necessarily owned by GCC; and, 2.) most importantly, no further information is available
about future potential sales in these areas as the markets are highly variable and speculative from year to
year. Although the Northern Mexico facilities are GCC-owned, Mexico is a different air quality regulatory
jurisdiction than the U.S where U.S. standards and regulations do not apply.
2.2.1.2 Regulatory Requirements
The regulatory framework for air quality includes both federal and state rules, regulations, and standards
promulgated by the Environmental Protection Agency (EPA) and implemented by the Colorado
Department of Public Health and Environment (CDPHE).The Clean Air Act (CAA) established the National
Ambient Air Quality Standards(NAAQS)for seven criteria pollutants.The criteria pollutants include carbon
monoxide (CO), lead, nitrogen dioxide (NO2), ozone (Oa), particulate matter 10 microns (PM1o) or less in
diameter, particulate matter 2.5 microns (PM2.5) or less in diameter, and sulfur dioxide (SO2) (Table 2.2-
1).
Pursuant to the CAA,the EPA has developed classifications for distinct geographical regions known as Air
Quality Control Regions. In Colorado, the state has been divided into eight multi-county areas that are
generally based on topography and have similar airshed characteristics.The Project Area airshed analysis
area (Section 2.2.1) lies in the Southwestern Air Pollution Control Region as designated by the State of
Colorado.The EPA designates whole or partial counties as Attainment, Non-Attainment, or Maintenance
for each criteria air pollutant. Regions classified as in Attainment are areas in which the pollutant has not
exceeded the NAAQS. A Non-Attainment classification represents an area in which the pollutant has
exceeded the NAAQS. The Maintenance designation is used when monitored pollutants have been
reduced from the Non-Attainment to the Attainment levels. La Plata and Montezuma counties have been
Dunn Ranch Area LBA and Mining Plan Modification 4
Technical Resources Report