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Under the No Action Alternative, the Deserado Mine LBA area would not be approved for <br />mining. Criteria, HAP, and GHG emission associated with the proposed LBA at the Deserado <br />Mine would not occur. However, as stated above, emissions rates or intensities would not <br />increase under either alternative and therefore the emissions inventory can reasonably be <br />expected to be the same for each alternative based on the fact that authorized production rates, <br />and currently employed extraction and processing methodologies would not increase or change <br />under either scenario. <br />Cumulative Effects: <br />Reasonably Foreseeable Cumulative Actions <br />The following actions within the region are known or are reasonably foreseeable. <br />• Potential Oil and Gas Development <br />• Potential Oil Shale Development <br />• Bonanza Power Station <br />The leasing decision for the Deserado Mine would not authorize mining operations. The EA <br />evaluates the potential impacts of mining the Deserado Mine, because mining is a logical <br />consequence of issuing a lease for continued operation of the mine. The EA assesses the <br />cumulative impact on the environment which results from the operation of the proposed mine <br />when added to other past, present, and reasonably foreseeable future actions that would add to <br />the anticipated impacts of the Proposed Action. <br />The site - specific impacts analyzed in this EA are based on the assumption that if the lease is <br />issued mining would proceed at the current production rate of approximately 2 million tons per <br />year. We further assume that the applicant would be the lessee and extraction of the coal <br />resource would proceed in accordance with all current permit conditions. In addition, it is also <br />assumed all of the coal will be consumed by the Bonanza Power Station. <br />Area Emissions <br />The following emissions data is presented to the reader to provide a comprehensive picture of <br />near field emissions sources. Given the distances between the Deserado Mine and other APCD <br />sources with the region (approximately 37 km on average), it is unlikely that the majority of the <br />mine's emissions (i.e., PM1o) which are not emitted via a smoke stack will become buoyant <br />enough to travel the distance required to provide for a measurable cumulative impact within the <br />region. The same can be said for oil and gas development in the region, which is significant. The <br />primary emissions of concern for these activities have traditionally been NOx and VOCs (ozone <br />precursors), neither of which are major emissions of concern from the Deserado Mine, and <br />therefore the mine's contributions of these emissions in the regional context should produce on <br />minor or insignificant impacts on potential regional ozone formation (see earlier discussion on <br />CMM VOC data limitations). <br />Emissions from the Bonanza Power Station have been most recently analyzed by EPA during <br />review of a construction PSD application for a waste coal -fired combustor unit (WCFC) that <br />Deseret Generation and Transmission Co- Operative recently submitted an application for. The <br />permit was eventually remanded back to EPA for failure to include COz BACT requirements; <br />however the statement of basis for issuing the permit for the other pollutants, and the associated <br />DOI- BLM -CO- 110- 2012- 0023 -EA 28 <br />