PERMFILE134363

• Permit No: C2008086
• IBM Index Class Name: Application Correspondence
• Doc Date: 12/7/2006
• Doc Name: Public Scoping Report for the Environmental Impact Statement
• From: BLM
• To: DRMS
• Media Type: D
• Archive: No

Scoping Comments"by the Region 8 Office of the
Environmental Protection Agency
Draft Environmental Impact Statement
Proposed Red Cliff Coal Mine
1. Purpose and Need/Alternatives/Project Description/Affected Environment.
The Purpose and Need for a proposal is the basis for identifying all feasible alternatives
that undergo environmental impact analyses in a NEPA document. Consequently, an adequate
and cleaz Purpose and Need statement will need to be developed and included in the EIS. All
feasible altematives Yhat would satisfy the Purpose and Need should be given equal consideration
and analysis. The EIS should include, but not be limited to, a "no-build" alternative. Several
altematives ranging from most protective of environmental and social impacts, to the action as
proposed by CAM-Colorado, LLC (CAM) should be included. At least one alternative should
emphasize conservation of natural resources, particulazly those deemed significant, rare, and/or
of high public value. Council on Environmental Quality (CEQ) regulations; which require
analysis of reasonable alternatives, clearly contemplate that an EIS evaluate reasonable
altematives that meet the purpose and need of the proposed action. The altematives analysis
"should present the environmental impacts of the proposed action and the alternatives in
comparable form, thus sharply defining the issues and providing a clear basis for choice among
options by the decision maker and the public." 40 C.F.R. 1502.14. Only by providing a broad
range of alternatives to consider in the Draft EIS process can the decision maker have latitude in
managing the development of the resource and their resulting environmental impacts.
The EIS should provide a detailed and accurate description of the various components of
the proposed action. All individual components (e.g., buildings, equipment, and project foot "
print) that make up the project azea, or any other project inftastructure, should be identified. In
addition, the EIS should include detailed project location maps, and figures depicting all project
areas. In order for the public and agency reviewers to understand the degree ofdirect, indirect
and cumulative impacts (impacts) of the project, the EIS should include a detailed
chazacterization of the affected environment. This would include, but is not limited to, providing
detailed descriptions of the resources in the study azea supported with photos and figures/maps "
that depict the various alternatives in relation to the study area resources. This information
should include, but need not be limited to, the identification of all wetlands, streams/rivers, lakes,
floodplains, forested or treed land, environmental justice communities, residences, Native
American tribe and resource concerns, and historic/cultural resources.
2. Cumulative Impacts.
In addition to the evaluation and discussion of direct and indirect impacts, the EIS should
provide cumulative impacts analyses for impacted resources of concern. The EIS should analyze
impacts according to airsheds and watersheds, rather than political boundaries. The cumulative
impact analysis should include additional coal and energy development activities. At this time, it