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Stsve Hinchmen, WSERC 4970/527-5307 tm1/22/99 04'49 PM ^3l4 we don't believe it is forbidden. In~ by using this process we may be able t~ain resolve conflicts and design a better project that will benefit everyone -industry, the community and neighboring citizens - overthe long term. To further that potential, WSERC has already begun discussions with the BLM and mine operators to set up a community discussion and working group to address the many issues we are facing. We would like to provide you with an example of how this could work to the interests of everyone. Many of the Technical Revisions before us now deal with Bowie's proposed new coal handling facilities. Bowie has applied for these upgrades predicated on the assumption that will never have access to the adjoining Tenor Creek rail loadout, which is owned by another company. We figure that the current proposal could result in huge numbers of trucks on the road -one every 1.5 minutes -and all sort of related impacts. However, a joint review process and/or community roundtable could possibly establish a means for dual use of the Terror Creek loadout. This might result in tremendous benefits: • It could eliminate the need for truck hauling on state highways, thus eliminating concerns over traffic, safety, air quality and impacts to those living near the road. • Bowie would be spared the expense of building new facilities or investing in additional trucks and equipment; or the expense of abandoning such infrastructure in the event a similar deal was worked out at a later date. • It could eliminate the need for some facilities altogether, and for duplicate facilities owned by separate companies, thus reducing environmental, surface and water impacts. • Oxbow, the current facility owner, tivould receive compensation for lease of its facilities. • The state DOT would have fewer impacts and maintenance concerns on its roads. • DMG would be relieved of a major permit revision; or of a second major permit revision should a similar deal be worked ou[ at a later date. • One of the largest points of conflict could be removed from the BLM's EIS process, thus speeding a final decision and helping to meet coal operator timelines. • Overall cumulative impacts on the community and environment would be lessened. This is just one example of why we need Ute opportunity to fully evaluate this proposal and related impacts in their entirety prior to permitting. Although this type of analysis may not fit DMG's traditional role and responsibilities, if you can find a way to help we may all be better off. WSERC would also like to point out that failing to do so would likely result in the highly negative impact of plunging the community back into conflict. As I am sure you are aware, the BLM vacated Bowie's proposed Iron Point Tract coal lease because of the failure to analyze impacts of increased production associated witlt a new longwall mine at Bowie, and the failure to analyze cumulative impacts of recent expansion at all the mines in the Paonia-Somerset Coal Field. The BLM has promised toconduct afull-scale EIS to disclose these impacts and to provide good information upon which the larger community can plan for impacts of this growth. Connected to this action, as I have already mentioned, community and industry representatives have already begun meetings to establish a coal mine discussion group. If the DMG proceeds with this application, then all these federal and community efforts will be rendered pointless. The proposed mine expansions will have already occurred, and the opportunity for the community to determine its own fate lost. Thus we would also like to register the above concerns in a more legalistic manner. It appears that the proposed technical revisions is premature due to applicants failure to establish a 'Right of Entry" under Section 2.03.6 of the Rules and Regulations of the Colorado Mined Land Reclamation Board Pursuant to the Colorado Surface Coal Mining Reclamation Act.