2012-02-09_REVISION - C1980004 - Laserfiche WebLink

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3400 (LLCONO3000) COC 125439 Dear Mr. Boulay: United States Department of the Interior BUREAU OF LAND MANAGEMENT Grand Junction Field Office 2815 H Road Grand Junction, Colorado 81506 www.co.blm.gov /gjra /gjra.html State of Colorado Division of Reclamation, Mining, and Safety Department of Natural Resources Attn: Mike Boulay 1313 Sherman Street, Room 215 Denver, Colorado 80203 RECEIVED FEB 09 2012 i�iv 5 ,ucsamation, Mining and Safety FEB 0 7 2012 TAKE PRIDE` INAM ERICA On November 30, 2010 I sent you a letter regarding McClane Canyon Mining, LLC's ( "MCM ") Permit Revision Application No. 2 (PR -2). The letter that I sent stated that BLM had not yet provided approval for the proposed mine expansion, and that my staff would be completing the environmental analysis for the MCM Permit Revision. After further consideration and discussions with the BLM Colorado State Office and Office of Surface Mining Reclamation and Enforcement ( "OSM ") this determination has changed. BLM will not be completing the environmental analysis of MCM PR -2 application. Instead we will be providing comments to you and OSM during the adequacy review and the environmental analysis for the permit revision. During our review we determined that the PR -2 proposal would not be in conformance with our current Resource Management Plan (RMP). We have identified several conflicts and concerns with the PR -2 proposal. The primary concern is with the potential impacts to visual resources. The PR -2 proposal is contained in an area that is designated as Visual Resource Management (VRM) III. VRM III designation allows for moderate changes to the landscape that attract attention but do not dominate the view. The proposed waste rock disposal pile would be placed within 400 to 600 feet of Colorado Highway 139, which is also designated as a National Scenic Byway. Other resource concerns that have been identified with the PR -2 proposal include impacts to a historic irrigation ditch still in use, proximity to a perennial creek, proximity to a maternity bat roost site, as well as potential impacts to a historic dam and prehistoric cultural sites, and changes in setting at prehistoric sites. Placement of a large waste rock pile as proposed would also change the post mining land use in the proposed location. These changes would result from impacts to VRM resources and existing grazing use. Design of a smaller pile may help to reduce impacts to many of the sensitive resources, although it may not be able to resolve all of the issues with the visibility of the location. The MCM PR -2 proposal includes placement of facilities from sensitive resources at the approximate distances listed below: