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Steve Hinehmnn, W SERC <br />Western <br />• <br />1t 9701527.5307 <br />Envlironmental <br />~t122199 ~4~4BPM ^114 <br />• III IIIIII'lllllllll <br />999 <br />Joe Dudash <br />Environmental Protection Specialist <br />1313 Sherman St Room 215 <br />Denver. Co. 80203 <br />Fax: (303)866-8106 <br />Hard Copy with attachments to follow by US \4ai1 <br />Re: Bowie No. 2 Mine (Permit No. C-96-083) <br />Bowie No. 1 Mine (Permit No. C-81-038) <br />Technical Revision Application Nos. 6, 7, &30 <br />122199 <br />This letter constitutes the comments of the Western Slope Environmental Resource Council <br />(WSERC) regarding Technical Revision Applications for Bowie Resowces, Ltd., coal mines and facilities <br />listed above. <br />VISERC is a grassroots environmental non-profit organization based in Paonia, Colo., and dedicated <br />to protecting and enhancing the environment and quality of life in Delta County and Colorado's Western <br />Slope. WSERC organized in 1977 and now has approximatel}~ 200 members. Impacts of coal development <br />are of great concern to our membership and we have been involved in coal issues since our inception. Our <br />members live adjacent to the mine areas and in the larger affected community. We are impacted by the <br />affects of these decisions in virtually every aspect of our lives: from the bumps in the local economy, to the <br />heated political atmosphere, to degradation of environmental conditions, to effects on our water rights, <br />homes and private property, to impacts on public lands and waters. <br />One of our primary concerns is the confusion caused b}' the segmentation of Bowie Resources <br />(Bowie) longwall expansion program into three or more separate minor technical revisions. In effect, TR #7 <br />for the conversion to the longwall, TR # 6 for new coal handling facilities, and TR # 30 for increasing train <br />loadout capacity, when considered together, constitute a major revision to Bowie's existing mine plans. For <br />example, these changes would fundamentally change Bowie's mining methods and process, quadruple mine <br />output, significantly increase disturbed areas within the permit boundary, significantly alter the existing <br />reclamation plan, and cause a series of unknown impacts off-site including changes in traffic, air quality, <br />water quality, employment, train schedules, etc. However Ute state Division of Minerals and Geology <br />provided little information about Utese potential impacts, individually or cumulatively, upon which we the <br />public can base our comments in this permit process. <br />We believe Utat rather than process Bowie s application as separate, unconnected technical revisions, <br />the Division of mineral and Geology should require an amendment to Bowie's mine plan that encompasses <br />all of the proposed actions. This also matches statutory requirements to conduct mine plan amendments <br />when a proposed action or series of actions would increase the disturbed and affected areas within the permit <br />boundary or significantly change the reclamation plan - as these revisions do. <br />Box 1612, Paonia CO 81428 Phone ~ Fax (970j 527-5307 wserc@rmi.net <br />