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November 17, 2011 <br />Christina Stark <br />Bureau of Land Management <br />Grand Junction Field Office <br />2815 H Road <br />Grand Junction, CO 81506 <br />Dear Christina: <br />RH /NO <br />ENE '# LW <br />I had a chance to talk to our engineer consultants and mine manager who <br />participated in the site visit on Monday, November 14, 2011 that was initiated <br />by the BLM to identify other potential coal refuse site locations. The need to <br />look at other locations is a bit perplexing to me. Other locations were <br />analyzed in the initial steps of this project in early 2010 and as a result, a site <br />was selected. It is not clear to me what the major issues with the proposed <br />coal refuse site location are. Several issues have been mentioned, but what <br />are the main issues that would cause BLM to identify and investigate <br />alternate pile locations so late in the process? I understand that a <br />compromise was discussed regarding the size of the pile. By designing a <br />smaller pile, it appears that any issues, (i.e., visual, the bat cave, the High - <br />lonesome ditch) could be mitigated. NEPA does not require alternatives to be <br />analyzed where impacts can be mitigated to acceptable levels. We believe a <br />smaller pile size will mitigate the issues to an acceptable level and should be <br />investigated more thoroughly. <br />Two significant issues that appear to be being overlooked are time and cost. <br />This process began in July of 2010 and does not seem to be anywhere near <br />the end. If the BLM requires analyses of an alternate coal refuse site(s), the <br />project could be delayed by a year or more. The cost associated with doing <br />additional resource surveys at potential site(s), (Cultural, Wildlife, Soils, <br />Vegetation, Geotechnical, etc) will amount to tens of thousands of dollars of <br />additional expense. We believe the delay in time and additional expense are <br />not warranted, nor required by BLM or NEPA, since the smaller coal refuse <br />site should mitigate resource issues. <br />Rhino Energy LLC <br />Phone (970) 245 -2987 • Fax (907) 242 -7908 <br />2352 N. 7 Street Unit B • Grand Junction, CO 81501 <br />