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federal mining plan by OSM is required for coal operations involving new federal coal ]cases, which <br />also includes modification areas. OSM is responsible for preparing and submitting to the Secretary a <br />decision document recommending approval, disapproval, or conditional approval of new mine plans <br />and permit modifications (30 C.F.R §746). Secretarial approval is required for new mine plans and <br />mine plan permit modifications even though DRMS has already granted a permit to mine coal. <br />Secretarial approval is not required for proposals that are considered mine plan permit revisions. For <br />further information about the roles and responsibilities of the various agencies in Colorado please see <br />attachment 1 (30 C.F.R. §906.3 Appendix B), please note that BLM assumes the rote of Federal Land <br />Management Agency and Mineral Management Service in this agreement. <br />As the Federal Land Management Agency, BLM conducted a review of the PR -2 proposal. During <br />our review we determined that the PR -2 proposal as submitted would not be in conformance with our <br />current Grand Junction Field Office ( "GJFO ") Resource Management Plan ( "RMP "). We have <br />identified several conflicts and concerns with the PR -2 proposal. The primary concern is with the <br />potential impacts to visual resources. The PR -2 proposal is contained in an area that is designated as <br />Visual Resource Management ( "VRM ") III. VRM III designation allows for moderate changes to <br />the landscape that attract attention but do not dominate the view. Your current waste rock pile would <br />cover approximately 13.6 acres of public land managed by the BLM. The proposed location of the <br />pile is in a narrow canyon that is approximately 850 feet to 1,100 feet wide that contains Colorado <br />Highway 139 and East Salt Creek. The proposed waste rock disposal pile would be placed within <br />400 to 600 feet of Colorado Highway 139, which is also designated as a National Scenic Byway. <br />Other resource concerns that have been identified with the PR -2 proposal include impacts to a <br />historic irrigation ditch still in use, impacts to permitted cattle grazing operations, proximity to a <br />perennial creek, proximity to a maternity bat roost site, as well as potential impacts to a historic dam <br />and prehistoric cultural sites, and changes in setting at prehistoric sites. Placement of a large waste <br />rock pile as proposed may also change the post mining land use in the proposed location. These <br />changes would result from impacts to VRM resources and existing grazing use. Design of a smaller <br />pile may help to reduce impacts to many of the sensitive resources, although it may not be able to <br />resolve all of the issues with the visibility of the location. I encourage CAM to consider alternate <br />locations for the waste rock pile with less potential impacts to visual resources and other sensitive <br />resources. <br />The PR -2 proposal includes placement of facilities from sensitive resources at the approximate <br />distances listed below: <br />• Coal Refuse Pile: <br />o VRM/National Scenic Byway - 400 to 600 feet away (pile 100 feet tall with multiple <br />benches) <br />o East Salt Creek - 200 feet away <br />o Large eligible historic site — direct impact <br />o Potentially eligible historic site — direct impact (requires data recovery) <br />o Eligible prehistoric site — direct impact <br />