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~~ _ v' ~.J 'r 5 According to the EAR, the applicant purchased its 120 acre tract o£ fee coal and undertook a drilling and evaluation ' program during which the company discovered that only about one-third of the tract contained coal of economic importance. :iowever, the applicant proceeded to invest several million dollars in mining facilities, coal storage and loading systems, a rail spur, and other improvements, which appears out of propor- tion to the fee coal under its control at the mine site. We believe that the applicant's investments at the site, complicated i by the applicant's further need for federal action in order to ~ make these investments profitable, does not reduce the company's °~ responsibility to mitigate the environmental impacts of its ,y! operations. The costs of adequate environmental impact mitigation measures are just as much a cost of doing business today as the • costs of labor or machinery and we do not believe that it is ' the responsibility of the federal government to base the size of a lease on what the applicant says it needs in order to justify ,j the risk that it took in investing so heavily in a :nine that contains only a small amount of fee coal. Further, environmental mitigation measures are available under current State rules and regulations. A third major justification contained in the State Director's memorandum is that the tiorthern Indiana Public Service Company (~IPSCO) needs coal from the proposed lease tract in order to satisfy an iPy order to reduce its emissions of SO2. Although _ NIPSCO may be using low sulfur coal in order to reduce its sulfur dioxide emissions, our Region V of `ices inform us that VIPSCO is not at present under any EPA order to reduce S02 emissions pursuant to Section 113 of the Clean Air Act. We believe that the cuestion of environmental benefits that may be obtained by using coal from the Orchard Valley :fine should not override the Bureau of Land t•Ianagement's responsibility to fully analyze and mitigate the environmental impacts of ~ mining and shipping coal, nor should it preclude the considera- ., tion of alternative sources of low sulfur coal and alternative ~ means for the utility to comply with clean air requirements. In spite of the environmental benefits of using low sulfur coal from the mine, we believe that it is unjust to expect ! t'~e citizens of the .lorth Fork Valley to accent environmental .j degradation without adequate consideration of mitigative ti measures and alternatives though the :~E2A process. ,~ 'y~ Finally, although this agency strongly supports the 9resident's _'" affirmation of the need to increase coal production in the Onited States, we hasten to add that his call for increased ~ production was balanced by a recognition of the urgent need to