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<br />,ENT °,- T United States Department of the Interior <br />?Q-;$1 ,\1i/!e yF'2 <br />N o OFFICE OF SURFACE MINING <br />Reclamation and Enforcement <br />g Western Region Office <br />'4scw a.'?Q 1999 Broadway, Suite 3320 <br />Denver, CO 80202-3050 <br />December 18, 2009 <br />Melissa Smeins, Geologist <br />0__Hbkol?_ <br />SM ?OFT? - <br />M <br />o a" <br />SURFAG??\ <br />CO-0049 <br />Bureau of Land Management .., .. <br />Royal Gorge Field Office <br />3028 E. Main St. <br />Canon City, CO 81212 <br />RE: New Elk Coal Company, LLC, Coal Lease Application, COC-071978, Draft <br />Environmental Assessment, DOI-BLM-CO-200-001 8EA <br />Dear Ms. Smeins: <br />The Office of Surface Mining Reclamation and Enforcement (OSM), as a cooperating agency, <br />has reviewed the above subject draft Environmental Assessment (EA). It is OSM's opinion that <br />the EA does not currently contain sufficient environmental and other resource information to <br />adequately address the requirements of National Environmental Policy Act (NEPA). OSM <br />strongly recommends that the Bureau of Land Management (BLM) delay publication of the EA <br />until additional analysis of environmental and other resource information for the lease-by- <br />application (LBA) and the surrounding area is completed. <br />OSM offers the following informal comments for BLM's consideration. <br />The entire EA is in need of a though editing to enhance clarity, readability, formatting <br />inconsistencies, and terminology usage. Furthermore the entire EA needs to reviewed for <br />justification of statements and internal consistency. Please see Cumulative Impacts of the <br />Proposed Action: Geologic scope; Time Scope, page 14. In addition, a glossary of terms would <br />be useful. For example, the terms "Geographic scope" and "Time scope" need to be defined. <br />In all critical elements the discussion of the existing environment needs to be enhanced to <br />provide a clear picture of the existing resources of the area. <br />Even though the lease-by application involves the leasing of Federal coal the EA needs to <br />address and consider the interaction of the leasing action with the private coal and private surface <br />owners. <br />ISSUES AND CONCERNS, page 1 <br />The paragraph implies that more than one ventilation shaft will be needed as mining progresses <br />north contrary to the discussions in the rest of the EA.