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• <br />Finally, the EA does not address the physical deterioration of the local roads and state <br />highways that will occur due to the proposed increase in heavy truck traffic. State <br />Highway 141 and State Highway 491 will receive the burden of transporting ore from the <br />study area. A significant portion of the highway segments are listed by CDOT as having <br />a Remaining Service Life (RSL) of 0-years. This means that the roads have deteriorated <br />to the point that only a major reconstruction of the roadway will fix the inherent problems <br />with the road surface. Currently, the State of Colorado has no money budgeted for road <br />improvements on these highways for at least the next 30 years. The EA does not address <br />the impacts that hauling up to 214,000 tons of ore per year will have on these roads, nor <br />does it discuss mitigation for these impacts. <br />CDOT appreciates the opportunity to comment on this EA and any future permits <br />impacts state highways, but is concerned that impacts to state highways and access <br />control issues have not been adequately disclosed or addressed. We request that the <br />BLM revise the EA to include impacts to the specific state highways affected by this <br />proposal and describe mitigation measure for safety, access, and road deterioration for the <br />proposed expansion. A Traffic Impact Study should be initiated, and the project <br />proponent needs to submit an application for a State of Colorado Access Permit. <br />Response: The Operator is required to comply with all state regulations, <br />including CDOT regulations. <br />• <br />The complete set of public comments and documentation of my evaluation and <br />consideration can be found in the project file at the San Juan Public Lands Center in <br />Durango, Colorado. <br />Decision Record 12 Sunday Mines Complex Expansion <br />Dolores Public Lands Office January 2009