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2008-06-20_REVISION - C1980007
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2008-06-20_REVISION - C1980007
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Last modified
8/24/2016 3:33:23 PM
Creation date
6/23/2008 9:47:20 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
REVISION
Doc Date
6/20/2008
Doc Name
Request of Rocky Mountain Clean Air Action for Formal Hearing on the Proposed Decision
From
EarthJustice
To
DRMS
Type & Sequence
TR111
Email Name
TAK
Media Type
D
Archive
No
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Irreversible and Irretrievable Commitments of Resources <br />Health and Safety <br />control measures are expected to minimize the <br />extent of this adverse effect to minimal levels. <br />If the No Action Alternative were selected, the <br />mining operations may slow substantially or <br />cease entirely due to unsafe levels of methane <br />making coal recovery uneconomical and would <br />result in a significant loss in the long-term <br />productivity of the West Elk Mine. This loss in <br />productivity would result in economic impacts <br />to the local economy as a significant number of <br />people within the community are employed at <br />the mine. <br />Transportation <br />Though transportation system modification <br />(upgrade and new construction) would be <br />considered long term, impacts to related <br />recreational use would be considered short <br />term. Use of the existing Sylvester Gulch Road <br />as primary access, with project related access <br />on NFSR 711 and associated roads would be <br />long term and for the life of the subsurface <br />West Elk Mine-coal mining operation. As <br />discussed in Chapter 2, proposed new roads <br />would be reclaimed upon completion of <br />methane drainage activities, while upgraded <br />roads would either continue to be maintained as <br />such in perpetuity (existing roads) or restored <br />to their original use (OHV-specific access). <br />Unavoidable Adverse Effects <br />Water <br />Under Alternatives 2 and 3, mining related <br />activities would occur, generating potential <br />short-term direct and indirect effects upon the <br />environment; however no unavoidable long- <br />term adverse effects are expected with regards <br />to surface water and ground water resources. <br />Soils <br />Despite project design criteria, BMPs, and <br />lease stipulations to minimize erosion during <br />implementation of Alternatives 2 and 3, some <br />loss of soil due to erosion would occur due to <br />wind and run-off, especially if run-off occurs <br />on steep disturbed slopes before BMPs or lease <br />stipulations are implemented. However, erosion <br />Also, excavation and stockpiling of soil would <br />destabilize soil aggregates (i.e. soil structure) <br />which would reduce water holding capacity and <br />increase susceptibility to erosion (Brady and <br />Weil 1999). <br />Under Alternative 1 continued mining related <br />activities such as installation of monitoring <br />wells and exploratory drilling, recreational <br />OHV use, and grazing would cause some <br />degree of unavoidable soil loss but this effect <br />would be much less extensive compared to that <br />occurring under Alternatives 2 or 3. <br />Vegetation <br />There are no unavoidable adverse effects on <br />vegetation resources. Species composition and <br />productivity might change as a result of site <br />reclamation and revegetation for up to 10 years. <br />Roadless <br />Past land use and development associated with <br />any alternative would continue to have <br />unavoidable adverse impacts on roadless <br />character within the West Elk IRA beyond the <br />life of the project. <br />Transportation <br />There are no unavoidable adverse direct <br />impacts to transportation system management <br />and use from any of the alternatives. <br />Livestock Management <br />Changed patterns of livestock use may be a <br />short-term unavoidable adverse effect resulting <br />from this project. <br />Social and Economic <br />Alternative 1 would have an unavoidable <br />adverse effect by reducing employment levels <br />at the mine, loss of personal income to workers, <br />loss of federal royalties and loss of tax revenue <br />to counties caused by the curtailment of mining <br />at the West Elk Mine. <br />Irreversible and Irretrievable <br />Deer Creek Shaft and E Seam Methane Drainage Wells Project FEIS 151
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