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-+ - -- - <br />.tED Si+, <br />Fy <br />< ~[ <br />~ ~ ~~~~' UNITED STATES ENVIRONMENTAL PROTECTION AGcNCY <br />.~ ~ ~~'+, FPOIEL` WASHINGTON. D C. 20460 <br />ti O1/ ~ 8 1977 <br />OFFICE OF THE <br />ADAM NISTRATOR <br />Mr. Guy Martin, Assistant Secretary <br />for Land and Water <br />Department of the Interior <br />Washington, D.C. 20240 <br />'t <br />_, . <br />Dear Mr. Martin: <br />a ?ursuant to our resFOnsibilities under Section 309 of the <br />,, Clean Air Act this Agency has reviewed the draft and final <br /> Environmental assessment Records (EAR'S) for the short-term <br /> lease application of Colorado Westmoreland, Inc., at the <br /> Orchard Valley Mine near Paonia, Colorado. We have also <br /> reviewed the recommendations of the Colorado State Office <br /> of the 3ureau of Land Management (CO-932 C-25079). In <br /> our previous comments to ~he State Director (See attached <br />' letter of August 11, 1977) we indicated that, in our opinion, <br /> any of the coal leasing alternatives addressed in the draft <br /> EAR would have impacts significant enough to warrant <br />' preparation of an environmental impact statement (EIS). Our <br /> conclusions were based on a variety of environmental concerns, <br /> including cumulative air and water quality impacts, the <br /> availabilit of water for agriculture, the noise analysis <br />1 contained in the EAR, the secondary impacts of the project <br />.y on municipal services (including sewage treatment), and <br />.~+~ procedural matters related to the environmental analysis of <br /> the proposed action. <br /> The State Director of the BL;`4 office in Colorado, by his <br /> memorandum of October 28, 1977, requested immediate approval <br />) to proceed with a short-term lease for the maximum reserves <br />~ (in one of the coal seams) that "can lawfully be offered <br /> at the time of approval." The State Director also recommended <br /> that no environmental statement be prepared for the lease sale. <br />J <br /> Upon reviewing the rinal EAR and the recoRanendations of the <br /> State Director in this matter, we find that we still have <br /> significant concerns about the oroposed action and we believe <br /> that the requirements of Section 102(2)(c) of the National <br />r <br />