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does not include authorization of a refuse pile that would meet your proposed needs. Based upon <br />calculations from BLM mining engineers your currently proposed pile may only last 10 years under <br />proposed production rates, or 15 to 20 years under more conservative production rates. Redesign of <br />the waste rock pile to address visual issues and other outstanding issues in the proposed location <br />would likely further reduce the available capacity and period of use of the pile, potentially to a very <br />short time period. Given the extent of issues and conflicts at the current location it may be more <br />prudent for CAM to consider additional or alternative sites for the waste disposal pile with fewer <br />issues than the proposed location. BLM is unlikely to recommend authorization of a refuse pile to <br />DRMS and OSM if it doesn't meet the needs of the reasonably foreseeable future. Authorization of <br />a smaller pile that does not support development in the reasonably foreseeable future may lead to <br />incremental decision making. <br />In summary, BLM will continue to work with OSM and DRMS through the review of your <br />proposal. If you chose to proceed with your PR -2 proposal, then I encourage you to work with a <br />visual resource modeling specialist to help with design of the coal refuse pile. I also encourage <br />consideration of alternative location(s) and development of mitigation in your proposal to reduce <br />impacts to other sensitive resources. <br />If you have any questions please contact Christina Stark at 970.244.3022. <br />Sincerely, <br />J <br />(Catherine Robertson <br />Field Manager <br />Attachment l: 30 C.F.R. §906.3 Appendix B <br />Attachment 2: 30 C.F.R. §746 <br />