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INTEROFFICE <br />John Hickenlooper <br />Governor <br />MEMORANDUM <br />Mike King <br />Executive Director <br />TO: Dan Hernandez, West Elk PR -15 File <br />Loretta <br />DirectoE. Pineda <br />FROM: Jim Stark <br />SUBJECT: USFS EIS Review <br />DATE: 8 July 2012 <br />Per your request and the MOU, signed 25 June 2012, I have reviewed the Draft <br />Environmental Impact Statement, prepared by the Paonia Ranger District, for Federal <br />Coal Leases COC -1362 and COC -67232 for the West Elk Mine. The main focus of my <br />review was on portions of the EIS that discussed the Division's role in the permitting and <br />review process following the issuance of the lease modifications. While I did read other <br />parts of the EIS, I did not focus on any of the science or scientific conclusions that were <br />reached. The following are the comments that I have regarding the EIS. <br />On page 36, under the heading "Shrink the boundaries... ", there is a statement <br />that "(t)his allows the DRMS to bond for surface reclamation." The preceding <br />discussion is in regards to projecting impacts, including those related to <br />subsidence. While the statement regarding the Division bonding for surface <br />reclamation is correct, the fact that it immediately follows a discussion regarding <br />projecting impacts related to subsidence may lead to the incorrect conclusion that <br />the Division bonds for the repair of subsidence related features, which is not <br />correct. I would recommend clarifying this with an additional statement that <br />would read something like the following. "Surface reclamation includes the <br />demolition and removal of all structures, backfilling and regarding all disturbed <br />areas, topsoil replacement and revegetation. Bonding for surface reclamation <br />does not include bonding for the repair of possible subsidence related features." <br />2. On page 79, in Section 3.4, under the heading "Alternative 3 Environmental <br />Effects" (in the paragraph just above "Cumulative Impacts "), there is the <br />following statement: "...subsidence monitoring is a requirement of the mine <br />permit issued by the Colorado DRMS. If surface cracks occur that affect other <br />uses (roads, trails, etc.), the surface management agencies have authority to <br />require timely on -site mitigation per the two subsidence stipulations identified in <br />