Laserfiche WebLink
We have been diligently working with BLM to mitigate other issues that have <br />been discovered on -site. The culvert that goes under the cleaning plant has <br />been redesigned for the 100 -year event per BLM request. The sediment <br />pond and new ditches and culverts will be redesigned for the 25 -year event, <br />per BLM request. We will diligently work with the BLM to mitigate impacts <br />with the current pile location, but we must know what those issues are in <br />order to propose mitigation that is acceptable to the BLM. <br />In addition, there is an approved Regional Management Plan (RMP) in place. <br />I understand that the visual issue at least, has become an issue due to the <br />proposed RMP. Why is the approved RMP not being followed? Why is the <br />BLM following a set of standards that may or may not take effect during the <br />EA process? <br />I also understand there were discussions regarding the need to size a pile <br />large enough to contain all refuse that could be generated from the entire coal <br />reserve base currently under lease by CAM - Colorado from the BLM. Please <br />substantiate why the BLM requires a pile size that is large enough to contain <br />waste that could potentially be generated from mining the entire reserve (26.6 <br />million tons) over a 50 -60 year mining term. The scope of the EA requires all <br />surface disturbance to be evaluated as associated with the proposed action, <br />and mining that will occur in the lease modification area. Nowhere in the <br />scope does it state that impacts from mining the entire 26.6 million ton <br />reserve will or should be evaluated. We do not believe BLM or NEPA <br />requires analyses of an entire 50 -60 year project, nor does the scope of work <br />for this project. <br />A response to these concerns would be appreciated by the end of this month. <br />We want to see this project continue to move forward in a timely manner, and <br />we will do our part to supply requested information as quickly as possible. In <br />addition, I would like to schedule a meeting to discuss how to move this <br />project forward; what will be expected from CAM - Colorado, and what will be <br />expected from the BLM. <br />Sincerely, <br />)A‘r <br />Corey Heaps <br />Cc: Catherine Robertson - BLM <br />Bridget Clayton - BLM <br />Mike Boulay - DRMS <br />Mary Bloomstram -Edge Environmental <br />JE Stover & Associates <br />Rhino Energy LLC <br />Phone (907) 260 -4650 • Fax (907) 242 -7908 <br />2352 N. 7'" Street • Grand Junction, CO 81501 <br />