APPCOR13205 - Laserfiche WebLink

Home Browse Search

. s ~ 2 Environmental Policy Act (PL 91-190) are applicable. ;Je ~~; believe that leasing at the levels contemplated in alternative leasing actions A through C of the State Director's ~~ memorandum clearly satisfy the criteria for preparation of an CIS pursuant to Part 1500.0 of the Council on Environmental `; Quality guidelines for preparation of environmental impact statements. Furthermore, we believe that alternative leasing action D of that memorandum is the only acceptable action. '~f This alternative lJOllld permit the Orchard Valley mine to remain in operation while environmental concerns about future ~•a leases and other coal mining developments in the study area are resolved within the framework of the West Central Colorado .. Coal Environmental Statement or a separate site specific EIS, Thus the Environmental Protection Agency requests the Department r,~ of the Interior to limit the offering of a lease (in response {•, to application C-?5079) under short-term criteria to sufficient reserves to produce no more than 700,000 tons per year for a maximum of three years. This Agency also requests that the ` ~ Department prepare an Environmental Impact Statement for the area of the coal resource in west central Colorado prior to s. ;:. offering any additional coal leases in the _+orth Fork Valley i=,. of the Gunnison River, Our specific reasons for this request ;';'.; and the results of our analysis of information provided to EPA ':_':'; are described below. I would appreciate your early considera- tion of our requests and ask that you notify us of your decision in this matter, Please contact me if a meeting is •..,~ appropriate to further discuss the issues. One of the principal arguments set forth in the State Director's memorandum is that the surface impacts of the various leasing alternatives would be no different from the impacts of present operations at the mine. Sde have difficulty accepting this argument because it does not account for the fact that many of the impacts associated with the proposed :pining activity are _.~ proportional to the level of production. For example, the •'"~ amount of road and rail traffic for coal hauling, the amount of waste material disposed of outside the mine, the number of '~ miners and skilled workers required, and the amount of water '~ recuired for mining that :night otherwise be available for agriculture or instream uses are all clearly related to the level o° production at the mite. ~~ .• *"'9 a