Laserfiche WebLink
2 <br />As mentioned above, the coal regulations provide BRL a right to a proposed <br />decision on PR-03 within 60 days of the informal conference, assuming that <br />technical adequacy issues have been resolved. This means that the Division <br />should issue a proposed decision on PR-03 by November 12, 1999, unless BRL <br />waives their right to that due date. The Division will continue to notify WSERC <br />whenever technical adequacy questions or answers become available, and will <br />continue to respond to WSERC's comments throughout this permitting process. <br />TRANSPORTATION <br />WSERC has significanf concerns with this proposal, specifically the plan to truck <br />5 MTY of coal along local roads. We insist that OMG take the following actions, <br />which are clearly within its statutory authority: <br />BRL must have in place air quality permits... monitoring must be set up... a plan <br />should be in place to resolve such conflicts. <br />As discussed at the September 13 informal conference, the Colorado <br />Department of Public Health and Environment (CDPHE) has issued air emission <br />permits to BRL that allow maximum annual coal production of 5 million tons per <br />year. BRL provided copies of those permits in their August 30, 1999 <br />correspondence to the Division. A copy of that material should be available at <br />the Paonia Public Library. The CDPHE is the agency with authority to issue air <br />emission permits and the legal jurisdiction to enforce the conditions of those <br />permits. Any conditions or monitoring plans required by air emission permits are <br />determined by that agency. The DMG required BRL to provide a list of other <br />required permits, such as air emission permits, in accordance with Rule 2.03.10. <br />BRL has complied with this provision of the regulations in their PR-03 submittal. <br />BRL must have authorization and verification from the Colorado Department of <br />Transportation that its highway ingress and egress points (including the junction <br />of old and new Highway 133's) meet state standards. <br />BRL provided copies of permits from the Colorado Department of Transportation <br />(CDOT) for road improvements in their August 30, 1999 adequacy responses to <br />the Division. The CDOT State Highway Access permits address improvements <br />of the junctions of the Bowie haul road with old State Highway 133. CDOT has <br />also issued permits to BRL for improvements of the junctions entrances and exits <br />from the loadout with the state highway. Those permits are included in TR-32 for <br />the Bowie No. 2 Mine. The improvements addressed in these DCOT permits will <br />need to be completed prior to implementation of BRL's proposed plans to haul <br />