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mine plan Cotter Corporation holds mine permit M-77-310 with the CDMG for the C-JD-6 lease tract. This permit authorized 6.24 acres of disturbance consisting of a waste rock pile (4.24 acres) and ventholes and access roads. The vent holes and access roads are located on DOE withdrawn lands. The waste rock pile is located on the Mineral Joe No. 18 and No. 19 lode mining claims and is associated with the lease tract. The waste rock pile was originally authorized by BLM Special Land Use Permit C-23834 on June 23, 1976 and converted to a BLM right-of-way reservation on 2/10/1988. The R/W expired on June 22, 1996. The RPN area will be incorporated into the plan of operations area and is included in CDMG permit M-77-310. The RNV will be closed on BLM records. The CDMG reclamation bond for this permit is $2,500; the DOE holds a bond for $19,000 and the tract is under lease to Cotter Corporation until March, 2006. The claimant of the Mineral Joe lade mining claims in 1977 was Kelmine Corporation. They filed with CDMG mine permit M-77.284 for disturbance of 9.5 acres on public lands. The mining and surface disturbance associated with this permit are two waste dumps, vent holes, drill holes, mine buildings, shop, office, shaft, powder magazine, power substation, powerlines, roads, Duggan Adit, rail track, ore cars, trailers, stormwater control features, equipment, underground storage areas, etc. In 1993, Cotter Corporation acquired the Mineral Joe claims and CDMG Permit M-77-284 from Kelmine Corporation. CDMG holds a bond for $12,000 on this permit. The mine is in inactive status but could open again 'rf the operator so desired. Until such time as new activity begins, either for mining or reclamation activities the operation will remain inactive. At the end of the mine I'rfe, reclamation of the surface will be completed in accordance with the two CDMG Mine Permits. B. No Action This aMemative would deny approval of the plan of operations. The lands were disturbed prior to the implementation of the 43 CFR 3809 regulations. Regulations in 43 CFR 3809.1-6 (a) states, in part, that the proposal will be analyzed in the context of the requirement to prevent unnecessary or undue degradation. All requirements for environmental protection are able to be adequately mitigated. The only situation that could dictate possible non-approval of a plan of operations is conflict with the Endangered Species Act of 1973, as amended. Because there is no conflict with the Endangered Species Act, the plan must be approved subject to any changes and/or additions necessary to meet the requirement of preventing unnecessary or undue degradation. Therefore, "no action" is not a viable alternative for this proposal. III. Affected Environment A detailed description of the affected environment may be found in three documents: The San Juan/San Miguel Resource Management Plan (SJ/SM RMP), dated September, 1985, the CDMG Permit No. M-77-310 (C.JD-6), dated July 31, 1979 and the CDMG Permit No. M-77-264 (Mineral Joe), dated June 16,1978, respectively. This EA is tiered off of the above three documents. Only the additions or changes from the above documents are analyzed in this EA. The operations are located on the northeast flank of Monogram Mesa and along the southwest Paradox Valley. The SJ/SM RMP shows the area is within the Mineral Resources Emphasis Area. Montrose County Roads EE17 and EE18 provide access to the mine permit areas. The subject area is located in sagebrush and pinon on the northeastern flank of Monogram Mesa above the Paradox Valley. The area is used by wildl'rfe and provides grazing for cows