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Montoya Gravel Expansion 17-A <br />An assertion was made that the Purpose and Need should have considered the federal policy, to <br />sell mineral materials at not less than fair market value (43 CFR § 3601.6(b)) and that the EA did <br />not properly discuss this. Again, the purpose of the document is to focus on impacts to the <br />environment. The BLM policy is to update appraised values of mineral materials each time a <br />new contract is issued. An appraisal was completed for this purpose on March 11, 2008. <br />Assertions were made that the cultural resources analysis is contradictory and deficient. <br />Statements in the EA that refer to "a high number" of cultural sites and to sites dependant upon <br />the "setting" are referring to the larger context of the Grandview Ridge, as opposed to the 15- <br />acre project area; this is not contradictory. The 15-acre project area no longer contains any <br />known sites because they were fully excavated and data recovery completed. There are also no <br />sites (with setting as an eligibility criteria) that are within visual range of the 15 acre proposed <br />expansion area. A mitigation measure is included to protect for unknown cultural resources, by <br />requiring monitoring of soil stripping to identify buried cultural resources and by providing <br />contingency measures for evaluation and data recovery should any be found. <br />Another comment asserted that the economic analysis is faulty by seeming to rely on <br />assumptions that gravel costs rely on production costs instead of supply and demand, and that <br />there is not a shortage of supply in La Plata County. BLM contends that supply and demand is <br />inextricably linked to production costs (including haul distance) and both must be considered <br />jointly. The economic analysis was focused on supply and demand within short haul distances of <br />Durango, not on the total supply in the entire county. The demand in the construction industry <br />would not be for gravel at any price, but for low cost gravel. Selection of the No Action <br />Alternative would inarguably affect the lower-cost, short-haul market. The errors that were <br />pointed out in Table 5 have been corrected in the Final EA; rationale used in the analysis is still <br />valid. Once again, the comment contends that the contract renewal is a noncompetitive sale with <br />economic impacts to other producers, when in fact, a competitive sale was conducted. <br />A final comment states that the air quality analysis did not consider impacts to surrounding <br />residential development. The EA does consider short-term, local impacts to air quality, and does <br />recognize the adjacent Three Springs development. The statement that dust would be confined to <br />the pit boundary is supported by rationale of wind direction and topographic barriers. <br />Additionally, the EA states that operations will continue at the current levels. Operations were <br />active at the time the Three Springs development was initiated. Therefore, the recognized low <br />level of impacts will not change from current conditions. <br />MITIGATION MEASURES: <br />1. The operator will comply with all State permits which relate to air quality. The operator <br />will implement those practices as such permits require, to control fugitive dust/particulate <br />emissions. Examples are listed in the text of the document in Section 2.3.1. <br />2. A BLM or BLM-permitted archaeologist will be present during all initial soil stripping <br />operations to monitor for subsurface cultural resources. The operator will contact the <br />BLM 10 working days prior to the start-up of operations so that an agency-approved <br />Contingency Plan can be prepared and be in place when soil-stripping operations begin. <br />The Contingency Plan will clearly describe in detail how the operator is to proceed <br />should subsurface cultural resources be found.