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3 ~x "-'. .~'- ,tiA ~~. ~.~ ., Our conclusion that production in excess of 700,000 tons per year would cause significant impacts on the environment was eased upon the probable adverse effects that induced copulation growth o~ould have on tie ability of local communities to provide adequate municipal services to all citizens (including those who have no connection with coal mining activities) and other environmental impacts that are related to increased levels of coal production. Since the mine is currently producing ap_nroximately 300,000 tons of coal per year (See Petition of Colorado :destmoreland, Inc. to Intervene as a Defendant in NRDC v. Hughes; DCDC Civil Action 75-1759) even the 700,000 tons per year production rate which we have indicated might be acceptable for a short-term lease allows for more than a twofold increase in production. This increase alone may entail impacts for °.~hich special mitigation measures may be recuired, however to compound these impacts by the greater than fourfold increase that would occur in attaining the desired 1,250,000 tons per year level of production would, in our view, cause :major environmental impacts which must be addressed in an EIS. ^he recommendation of the State Director for i-~mediate action on the largest lease permissible by law appears to rest on four major elements. The maximum lease would; (1) provide for the most logical and efficient recovery of the coal reserves, (2) maintain or enhance the economic viability of the lease applicant's operations and contribute to the local economy, (3) enable the coal purchaser to acquire long-tern suaplies of coal that are required in order to comply with an EPA order to reduce SO2 emissions, and (4) ~:.eet the President's call for an immediate increase in coal production. ?irst,~we agree that if the coal in the proposed lease tract is to be mined at all it si~ould be done in a manner that assures the most efficient and complete recovery of the coal resource that is possible. :1e do not, however, believe that Leasing the maximum axtent of the D seam is the only way of accomplishing this objective, nor do we believe that a lease of the scale that we could find acce~tabLe conflicts with the objective of maximum recovery of the coal contained in the D sewn. An alternative approach that we believe would accomplish *_his objective •~rhile allowing sufficient time to resolve our environmental concerns and complying with the court order in :~EDC v. Hughes (DCDC Civil Action 75-17?9)