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5 <br />All of the required maps and cross sections as outlined in 43 CFR 3480 are <br />included in the R2P2 package. <br />Tne R2P2 package contains text outlining how Maximum Economic Recovery <br />(MER) will De achieved. The mining engineer in charge of reviewing this <br />package agrees that MER will be achieved on the five (5) Federal Coal <br />Leases discussed in the R2P2 package. <br />Based upon the analysis presented, this office recommends approval of the <br />R2P2 package as it would insure Maximws Economic Recovery and would De in <br />the Dest interest of the United States of A~erlca. <br />In regard to other areas of the subject trans~tttal the White River <br />Resource Aree of the Bureau of Land Managemnent provided the following <br />comments. <br />We have no additional stipulations for inclusion in the permit, however, <br />we do have the following concerns: <br />1. It appears that OSM is not entering into consultation procedures <br />with the USFWS regarding black-footed ferret and possibly endemic <br />Colorado River fishes as required to Section 7 (a) of the <br />Endangered Species Act. <br />2. Tne increase in size of the refuse disposal areas adjacent to <br />Da n+in Reservoir has eliminated the effectiveness of the <br />reservoir as a stock water facility. We feel a replacement <br />reservoir should be constructed at another site and we will <br />pursue this through OSM in the near future. <br />3. We feel 8LM should receive copies of pertinent <br />reclasiatton/maltigatlon data Such as the study concerning mule <br />deer and pronghorn ^ovemmrnts. <br />4. There is no evidence theta SNPO determination of eligibility has <br />been obtained for cultural resource sites 5R8 1055, 1068, and <br />1072. Until a determination is obtained no activity should be <br />permitted which might endanger the Integrity of the sites. If a <br />mitigation plan is applicable, BLM should receive a copy. <br />Additional comments were also received fmroo a staff hydrologist and are as <br />follows: <br />Tne existing lease stipulations and permitting authority regulations <br />appear to adequately address the possible Impact to hydrology <br />resources form the new mining developmmment scheme. However, samne <br />concern exists regarding the CMLRD Findings Document for the original <br />permit application package. <br />m ~+ ~ <br />