Laserfiche WebLink
contemplated for the Box Canyon area coal lease has much less surface impact than oil and gas <br />exploration or production. <br />More importantly and fundamentally, these stipulations should not be made part of this lease <br />• because, an EA likely will need to be completed prior to any surface disturbance proposed. <br />Stipulations of the type at issue will be best addressed through the SMCRA permitting process <br />when a more focused environmental analysis of the actual mining plan will be scrutinized in detail <br />by all appropriate federal and state regulatory entities. In comparing recent leasing terms and <br />stipulations from the EA (~L)-93-24) associated with the nearby Jtunbo Mountain coal lease <br />(#COC-54558), we find that none of the previously desrnbed stipulations were imposed. <br />In summary, MCC believes that the excessiveness of the stipulations conflict with the BLM <br />resource recovery requiremeats and decreases reserve value by impairing the lessee's abt7t'ty to <br />evaluate the resource and safety and roaccically recover the reserve. S'tmilariy,'future <br />exploration and mining activities within the adjacent Raven Gulch area are jeopardized by this <br />same apparent conflict between the BLM's resource recovery goals and surface management <br />restrictions. <br />MCC has demonstrated a long history of environmental compliance and is not suggesting that <br />environmental standazds be compromised, but the encumbrance of restrictions which disallow the <br />safe and ethcient recovery of the reserve does not serve the government, industry, or the public. <br />MCC believes that the BLhf should remove those lease stipulations which place the recovery of <br />the coal at risk and reduce the value of the Box Canyon reserves. <br />MCC proposes that BLM exclude the stipulations from the lease and the parties work together in <br />the permitting process to meet the mutually desired land use goals. As such, we request a <br />• meeting with BLM, the USFS and Mountain Coal Company at the earliest possible time to avoid <br />a delay to the leasing schedule. <br />Si:.cerely, <br />~G ~c C, c. <br />G. E. DiClaudio <br />President <br />Mountain Coal Company <br />xe: Jim Edwards - BL~f State Office <br />T. O'Connor <br />S. Anderson <br />• <br />