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C.`~ Ob ~ `O 0~ <br />STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303J 866-3567 <br />FAX: (303) 832-8106 <br />March 20, 2008 <br />Ms. Catherine Robertson <br />Bureau of Land Management <br />Grand Junction Field Office <br />2815 H Rd <br />Grand Junction, CO 81506 <br />Re: Preliminary Draft Environmental Impact Statement <br />Red Cliff Mine Project <br />Dear Ms. Robertson: <br />COLORADO <br />DIVISION O F <br />RECLAMATION <br />MINING <br />- &- <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Hams D. Sherman <br />Executive Director <br />Ronald W. Cottony <br />Division Director <br />Natural Resource Trustee <br />Thank you fbr the opportunity to provide comments on the Preliminary Draft <br />Environmental Impact Statement (PDEIS) for the Red Cliff Mine project. The Division <br />of Reclamation, Mining and Safety (DBMS) has the following comments. <br />i. In oulr earlier comments, we had reconunended inclusion of a discussion <br />regarding the coal outcrop fire located within the project area. The "Hot Point <br />Fire" is referenced in amended narrative on page 3.2-17, under "Affected <br />Envi:ronment/Coal Geology", in Chapter 3. The narrative indicates that the <br />outcrop fire is located near the southern edge of the existing McClane Canyon <br />Mine leases, and that remediation is being planned for the fire. The outcrop fire is <br />not addressed in Chapter 4, "Environmental Consequences and Mitigation". <br />Surface disturbance activity in the vicinity of the outcrop fire could potentially <br />provide additional oxygen to the fire, exacerbating the existing situation and <br />complicating any future remediation efforts. Coal extraction operations could <br />also impact, and be impacted by the fire, depending on the seam being mined and <br />location of the areas of proposed extraction relative to the outcrop fire. <br />We recommend that these concerns be addressed in the appropriate sections <br />of Chapter 4. Ideally, the Hot Point Qutcrop fire zone and adjacent areas <br />should be avoided by construction activity associated with the Red Cliff mine <br />project. This may be the case, but clarification should be provided regarding <br />location of the outcrop fire and coal seam(s) affected by the fire, proximity of <br />proposed surface disturbance to the outcrop.fire, and coal seams that would <br />potentially be extracted in the vicinity of the outcrop fire. The potential for <br />office of office of <br />Mined Land Reclamation Denver • Grand Junction Durango Active and Inactive Mines <br />