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r v v .,hi y is to issue a lease for sufficient reserves of coal to enable the successful bidder to obtain 2,100,000 tons of coal on the advance, with stipulations that access to the coal remaining in the D seam will not be jeopardized by removal of pillars. This would alloy orderly mining of a logical mining unit cvithout committing the coal resource beyond the legally permissible limits, and it would not foreclose the option of continuing orderly 32velopment upon completion of the ` necessary environmental studies, if the studies justify ~ a further mining at the site. A~ Secondly, c.P~ is sensitive to the need to assure stable h;•' employment opportunities in the study area consistent with environmental protection. Sde support short-term additions to the coal resources of qualified e::istirg orerations when sufficient information is available to shoca that the primary and secondary impacts oz such actions will not be highly significant. The rc-commendations of the State Director, however, imply that a three-year 12352 based upon the January 1977 coal salt contract would create a "revolving door" situation in which successive. short-term leases would be required every three years, leading to uncertainty about 2maloyment in the mine, periodic mine closures and maintenance problems, problems for the local canmunity in planning for ±-tpact mitigation, and insufficient economic return for the operator to justify investments in environr..ental control measures. :•le believe t'.~at a revolving door situation is ~~ighly unlikely because short-term leasing :could enable a _ualified existing operation to remain active while the environmental and policy implications of larger, lone-term ,S leases are analy2ed. Gnce these analyses have been completed, ~7 short-term leases may be `.ollowed by more estensi•oe leases if policy and environmental conditions Hermit. In the case of the Orchard Valley '4ine, we ~riew a s:-iort-term lease to a qualified ~ successful bidder, follo;ved by a larger lease, as a far more ~ likely crospect than a revolving door situation involving a : series of small short-te ^t leases, tie also believe that a ' modest short-term lease allows the local community to enjoy a r2lacively stable level of employment at t`,e Orchard Valley I ~?ine and other mines in c:ie area, Pinally, -ae do not believe „y that a lease of the size that we nave suggested above penalizes .- the applicant, who has apparently invested with the hopes of obtaining a large federal coal lease, io allow a larger --- lease -:~ithout an environaiantal stacHmant would show disregard , for t:~e procedures tP.3t :1dV~ been established to assure that federal coal leasing actions are conducted in an orderly and ' 2nviror~encally sound ;eay.