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• s <br />•BLM must determine the extent and limits of the property rights at issue; <br />•BLM must determine whether the proposed operations are reasonably necessary; <br />•BLM must determine whether there aze less damaging alternatives; <br />•BLM must determine whether the proposed operations would cause undue <br />degradation of the federal resources; <br />•BLM must determine the proper extent of allowable interference with the other <br />multiple uses of the azea. <br />In addition, the Deputy State Director, Resource Services, BLM, in the attached letter of <br />November 24, 1997, recognized that, "the Bureau of Land Management has some involvement <br />with protection of the federal government's administration of the federal surface estate of the <br />land proposed to be mined." In spite of this recognition, BLM personnel have indicated that <br />they do not intend to comply with the NEPA analysis and NEPA public involvement <br />requirements. <br />The central request of this letter is that you direct the San Juan Resource Area to comply with the <br />procedural and substantive requirements of NEPA and all other applicable federal laws. These <br />procedural requirements of NEPA aze not optional and were designed by Congress to provide <br />substantive protections for the human environment. In addition to compliance with NEPA, the <br />process of preparing an Environmental Impact Statement will help identify and ensure <br />compliance with the other federal land management laws and other federal regulatory authorities <br />that apply to this gravel mining proposal. <br />We look forwazd to your prompt response to this request and cooperative participation in scoping <br />and other facets of the NEPA process. <br />Respectful <br />/ ,. <br />Travi .Stills <br />Counsel for: Susie and Rick Bell, Betty and Buck Morris, and Rick and Lynda Emerson <br />cc: Mike Long, Director, Colorado Division of Minerals and Geology <br />