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~-21-1999 7:0dPM <br />GIHON <br />EFFERT <br />rc <br />~ A KESS AT LAIC' <br />FR01.1~I HON <br />ASSOCIATES 303 d36 9396 <br />Mr. Chuck Williams <br />Page 9 <br />June Z 1, 1999 <br />page (4-13) by stating "Since these are existing water rights, impa~=ts of the water <br />withdrawal have been accounted for and will not be evaluated further." <br />P. 10 <br />xi. EPA also raised a number of other matters relating to air quality, :alternatives <br />analysis, pollution prevention, contingency plans, subsidence con~TOl and <br />mitigation, etc. that were not adequately addressed in the DEIS. <br />F. The DEIS Docs Not Consider All Reasonable Alternatives to the Proposed <br />Proiect_ <br />The DEIS is defective because it does not consider a reasonable range: of alternatives <br />as required by NEPA and the CEQ regulations, The attached comment letters provide examples <br />of alternatives the BLM reasonably should have considered. In addition: <br />The DEIS analyzes only three alternatives: the proposed action, an accelerated <br />action, and no action. Conspicuously missing is an alternative of a smaller action. <br />It is unclear why the BLM must approve the use of all of the leased lands at this <br />time, and particularly why EPA must approve all 550 wells to be used over the <br />next 30 years, especially when so much crucial information about the effects of <br />those wells is missing. Thus, a reasonable alternative ro the BLM action is to <br />cotuider and approve a smaller area of leased land upon which infection wells may <br />operate. Amore honest and open scoping process would have id~:ntified this as an <br />important alternative to be considered. <br />ii. To comply with its NEPA obligations, EPA must similarly consider all of its <br />reasonable alternatives, especially if they were not considered by the BLM in its <br />DEIS. The smaller action alternative is particularly applicable to the EPA UIC <br />pemritting process. American Soda has requested an arcs permit for 1,030 acres <br />of land. ]n light of the lack of baseline data on water quality and the existence of <br />USDWs, it is in the public interest, upon an adequate assessment of the <br />environmental impacts, for EPA to consider approving an area pe:nnit for a <br />smaller area or to requite American Soda to obtain a permit for each well. <br />iii. BLM's and EPA's failures to consider all of the reasonable alternatives are in <br />direct violation of NEPA. <br />9 <br />