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~, <br />~~} Mr. J. Paul Storrs <br />~ February 21, 1978 <br />~• Page Two <br /> <br />We appreciate EPA's statement that it is not th' <br />intent to unduly delay approval of an adequate minin <br />but we note that EPA seems to assume (a) that the mi' <br />plan must be "revised" to reflect both the BLM lease <br />stipulations and the interim environmental protectio. <br />standards recently promulgated by the Office of Surf <br />Mining Regulation and Enforcement; and (b) that the <br />"revised" plan must then be the subject of a new 50 <br />notice period before any action may be taken. <br />We respectfully submit that the plan fully des <br />how CWI will comply with the applicable standards, <br />further revisions of the plans are required, and th <br />plan may be approved as it stands without the requi <br />of publishing an additional 30 day public notice of <br />availability followed by a 20 day notice of intent <br />Of course, U.S.G.S, is empowered under its exi <br />regulations to approve mining plans upon conditions <br />require modification of the plan after it is approv <br />CWI will be required to conduct its operations in c <br />caith the obligations and standards of performance i <br />OSM and U.S.G.S. regulations, the provisions of all <br />applicable laws and regulations, the terms and cond <br />of its lease, the mining plan as approved, and any <br />issued by U.S.G.S.. <br />The EPA comments to your office on our mining <br />contained observations concerning the following gen <br />areas: (1) recovery of the resources; (2) spoil pla <br />and drainage and sedimentation control; (3) mainten <br />diversion structures; (4) revegetation; (5) stabili <br />post-mining slopes; (6) environmental monitoring; <br />availability; (8) temporary coal storage and crushi <br />facilities; and (9) subsidence. In many respects w <br />the EPA comments reflected a failure to review or t <br />stand data which was contained in the plan. In oth <br />respects EPA has requested us to furnish the basis <br />conclusions which were reflected in the plan. In r <br />to EPA's comments we are providing the attached mert <br />which responds to each of EPA's concerns. <br />it <br />plan, <br />ing <br />ce <br />bes <br />t no <br />the <br />lent <br />approve. <br />or to <br />and <br />nliance <br />Cher <br />ions <br />ders <br />lent <br />e of <br />of <br />water <br />feel <br />under- <br />sponse <br />randum <br />i i <br />I~ ~I~~i ;I~I~~~ ~fl~.~ h <br />~,~ <br />