COMPETITIVE APPLICATION NM 26093

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COMPETITIVE LEASEAPPLICATION NM 26093BLM LIBRARY88026009SUPPLEMENTus. DEPARTMENT OF THE INTERIORBUREAU OF LAND MAUAOtUlHT «

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(&d o' lSufP'EA No. NM-010-9-692CFI\BUS LibraryD-653A, Building 50Denver Federal CenterP.O. Box 25047Denver, CO 80325-0047SUPPLEMENTENVIRONMENTAL ASSESSMENTCOMPETITIVE LEASE APPLICATION NM 28093United States Department of the InteriorBureau of Land ManagementAlbuquerque DistrictAugust 1979BUREAU OF LAND MANAGEMENTLibraryPenver Service Center

PURPOSEThis supplement contains letters received in the public reviewprocess of the environmental assessment on the proposed leasingof coal for Competitive Lease Application MM 28093.Fourteenletters concerning this competitive lease were received fromvarious govenmental agencies, industry, and a private citizen.Responses to specific issues raised in these letters are includedin this supplement.The public comments that were received either require minorchanges or do not warrant further agency response, therebyalleviating the necessity for reprinting the enviroamentalassessment in its entirety.Copies of this assessrient areavailable fron the Bureau of Land Management, AlbuquerqueDistrict Office, 3550 Pan American Freeway N.E., Albuquerque, NewMexico 87107.

EfJVIRONMENTAL IMPACT STATQ1ENT DECLARATIOMA review of this environmental assesstnent indicates that therewould be no significant impact on the human environment thatwould necessitate preparation of an environmental Impactstatement.Based on the findings listed below, a decision not toprepare an EIS on this lease application has been made.The coal would be rained by underground raining techniques1adjacent to an existing mining operation, resulting inrelatively minor additional impacts.The proposed action would afford very little change in2.employment, placing relatively small additional demands onthe infrastructure,The BLM has encountered no opposition to the possible3.leasing of this tract.Holders of rights-of-way on the proposed lease area are4.agreeable to leasing.Issues addressed in public comments needing further5.assessment would be analyzed prior to exploration and miningplan approval.- a«ite /T, 'fj IIII—rnr-TirAppiegaLePaulDistrict Manager, AlbuquerqueBureau of Land Management,L.

LETTERNO.United States Department of the InteriorINHERITAGE CONSERVATION AND RECREATION SERVICESOUTH CENTRAL REGION5000 MARBLE AVENUE. N.E. ROOM 211ALBUQUERQUE, NEW MEXICO 87110REPLY BEFER TO:August 1, 1979Mr. Paul ApplegateDistrict ManagerBureau of Land ManagementP. 0. Box 6770Albuquerque, New Mexico 87107Dear Mr. Applegate:This is in response to your request for comments on the EnvironmentalAssessment for Competitive Lease Application, NM 28093, concerninga proposed lease and mining of Federal coal reserves on 3,855 acresnear Farmington, New Mexico. These comments are being provided on acoordination/ technical assistance basis.1-ABecause of the fact that there are many known archeological sites inthe proposed lease area, at least ten of which may be eligible forthe National Register of Historic Places, we recosanend early consultationwith the State Historic Preservation Officer. If possible, thisconsultation should occur prior to granting the lease, in order todetermine whether the cultural resources present on the site are ofsufficient value to Justify delaying approval of the lease.We appreciate the opportunity to comment on this proposed lease at thistime.Sincerely ipurs.RoilanS T HandleyRegional DirectorRESPONSE TO LETTER NO.1-A1If a decision to lease is made in resoonse toCLA NM 28093, the BLM will comply with the provisionsof Executive Order No. 11593 and the provisions of theNational Historic Preservation Act of 1965, as amendedprior to any terrain disturtance.1

LETTERNO.DIVISION OF CONSERVATION ARCHAEOLOGYii!San Jiun CountyMuseumAssociationAugust 6, 1979District ManagerBureau of Land ManagementP.O. Box 6770Albuquerque, New Mexico 87107Reference:Assessment and comments regarding the EAR for CLA28093; cultural resoxirces.Dear Sir:Ve have examined your EAR for Western Coal's lease applicationand find it to be basically adequate as an initial assessment of thearchaeological sensitivity of the area.Additional archaeological work, however, has recently beenperformed by our organization on Western Coal's existing San JuanMine Lease which provides additional information pertinent to thesignificance of the kinds of cultural resources which have beenfoiind within the Competitive Lease Application area.In terms of the prehistoric resources, it is anticipated thatthe most populous class of sites will fall within the Pueblo IIearly Pueblo III periods (ca. A.D. 1000-1200). This projection isbased in survey data collected by San Juan College and the Divisionof Conservation Archaeology on the San Juan Lease, by the BIA onUte Mountain reservation lands directly north of the lease, and asurvey by the DCA of one section located southeast of the CLA 28093'area. Sites attributable to these time periods have also beendociimented within the lease application area. Although the bulkof these resources are small one to four-room ''farmhouses", we havefound they are significant in that they collectively provide valuableinformation concerning prehistoric dry land agricultural practicesand the negative consequences of heavy agrarian dependence. Perhapsmore importantly, we feel that these resources will illustrate andwill help to identify those environmental and cultural factors whichwere significant in producing the collapse of the Puebloan socialand economic systems and the eventual abandonment of the Four Cornersregion by the Anasazi.The historic period sites are also important outcomes of earlyAnglo economic development within the area. A number of documentedsites within the CLA 28093 area are early 20th century homesteads whicrepresent an interesting and unique phase in the history of Anglo useand occupancy of the Farmington-Fruitland region. A few Navajo andUte sites probably exist within the proposed lease area. Our findingsshow that these sites specify interesting Navajo -Ute -Anglo interrelationships within the early portion of the 20th century.Stn Juan County Archaeologicil Research CenterRte3,Boxl69 Fannin«ton,New Mexico 874016 & Libniy(505) 632-2733 or 632-2013

LETTERNO.2.CONTINUEDDistrict Manager, BLMAugust 6, 1979Page 2What ve are attempting to show here is that the resoiirces exhibitscientific, historical, heritage, and educational values. We arguethat further inventory and assessments of the cultural resources2-Aare warranted and necessary prior to mining and related activities.Further, we recommend that tnese resource assessments be conductedwithin a problem-oriented framework Buch that the cultural valuesof the resources can be properly identified.II have one additional comment on the adverse effects on theresources as a product of subsurface mining.I have personal experienceexcavating archaeological sites affected by 19th century coal miningin northeastern Pennsylvania. Subsidence is both a long and shortterm adverse effect, whether or not underground pillars are left inplace. Subsidence-related effects on resources include not onlystructural degradation of architectural and other features, butalso serious disruptions of cultural and natural deposits.Thank you for the opportxinity to comment on your EnvironmentalAssessment Report.Sincerely,Meade F. Kemrer, Ph.D.Research DirectorMFK/taRESPONSE TO LETTER NO. 22-AIf a lease is issued, it will contain a stipulationthat an intensive inventory of cultural resources becarried out prior to approval of a raining plan (seeAdditional Recommended Mitigation, Table r-3, pageAuthority to condition mineral leases to insureI-I3).the protection of cultural resources exists under theMineral Leasing Act of 1920, as amended andsupplemented (30 U.S.C. I8I et seq.). Under authorityof this act the lessee may be required to bear theexpense of compliance with stipulations.

LETTERNO.3United States Department of the InteriorINREPLY REFER TO:HERITAGE CONSERVATION AND RECREATION SERVICESOUTH CENTRAL REGION5000 MARBLE AVENUE. N.E., ROOM 211ALBUQUERQUE, NEW MEXICO 87110August 15, 1979Mr. Paul App legateDistrict ManagerAlbuquerque DistrictBureau of Land ManagementP. 0. Box 67703550 Pan American Freeway, NE87107Albuquerque, New MexicoDear Mr. Applegate:This is in response to your request for comments on the environmentalassessment for the proposed leasing of federal coal in response toCompetitive Lease Application CCLA) NM 28093. These comments are beingprovided on an early coordination/ technical assistance basis and shouldnot be construed as an environmental statement review.We note that any mitigation efforts will be coordinated with the StateHistoric Preservation Officer. However, in addition to this action, theState Historic Preservation Officer should be contacted prior to any3-Asite surveys and given the opportunity to comment on the proposed actions,His comments should be documented in any further statements.y ncerely yours,Rolland B. HandleyRegional Directorcc:Mr. Thomas MerlanRESPONSE TO LETTER NO.3-A3The State Historic Preservation Officer will becontacted prior to the intensive archeological surveythat will precede approved of any raining plan.

STATE OFNEW MEXICOLETTERNOENERGY AND MINERALS DEPARTMENTENERGY RESOURCE AND DEVELOPMENT DIVISIONPCBTOmcx BOXBRUCE KING2113 WASHINGTON AVSOVEIMORSAMTAFE.NEW MEXCCOO&l 827 471LARRY KEHOEBCRTTARVAugust 17, 1979District ManagerBureau of Land ManagementP. 0. Box 67703530 Pan American Freeway, N.E.87107Albuquerque, New MexicoDear Sir:Thank you very much for asking for comments on the environemntal assessmentThe assessment would be morefor competitive lease application NM 28093.meaningful if more data and information were included, particularly, inthe following areas:1)Resource evaluation - drill hole location and data for the4-A 24 exploratory holes should be given and the method of calculatingcoal resources in place for each seam should be totheStateBeaumont,Geologist indicate 80 million tons of resources in place in the 3856acres - or considerably less than the 147 million that appear to beindicated in the A.Development drill holes - a drill hole spacing of 100 feet isindicated.The total number of expected drill holes should alsobe given and the area of expected drilling should be shown.Thetype of drilling, air, mud, etc., should be discussed along with howmany sites can be reached by driving cross country without roads,4-B ifetc.The data to support a 50 foot radius of soil disturbance foreach hole drilled should also be indicated, as I have seen areas largerthan this disturbed during drilling.Finally, legal requirementsfor rehabilitation, both on privately held surface and Federally heldsurface should be discussed.2)Status of private surface land holders - a discussion of the land4-c use, attitude of the private land holders of the surface propertyshould be given.etc.3),Resource commitments - a detailed discussion of resources usedfor i; room and pillar with no pillar robbing, 2) room and pillar4-D with pillar robbing, and 3) long or short wall mining should be given.Resources should include workers, electricity, diesel, and water on aresource consumed per ton of coal mined basis.4)10

LETTERA I St 17, 1979NO.4.CONTINUEDResource recovery - technical description of various miningtechniques including pillar robbing and long wall should be outlinedwith percentage of expected coal recovery included. The descriptioncould include the possibility of recovery of all seams greater thanBackfilling as a means ofthree feet in thickness in the Fruitland.allowing for recovery of upper coal seams through increased stabilityshould be included. The technical aspects of mining a 15 feet thick earn to its entire thickness should be indicated.The amount of itethanein the coal bed and possible drainage and use of the methance shouldbe discussed. The legal requirements in the mining plan approval etc.,for full resource recovery as is available from state of the art techniques should be stated.5)Loss of other energy resources - if subsidence occurs gas in theformations above the Fruitland could migrate out of these formationsand be lost. Drilling and shaft sinking activities involved withrecovery of resources in formations below the Fruitland will be moredifficult if the Fruitland coal is mined. A more detailed discussionof possible loss, increase in recovery costs, etc., of other resourcesdue to mining the Fruitland coal is needed.6)7) Subsidence - a very detailed discussionCbased on overburden thickness and characteristics, number of seams mined, mining techniques, andother factors influencing subsidence) of various types of subsidence asa function of mining technique is needed, subsidence due to pillarrobbing different- than that due to long wall mining and their resultinghazards are different. The discussion should try and allow the readerto realize trade-offs between costs, increased coal recovery, loss ofsurface for productive purposes, leakage of surface drainage waterdownward, increased erosion and loss of dams due to subsidence and otherenvironmental effects, loss of cultural resources, etc. Mitigatingtechniques such as back fill should be indicated. Legal requirementswhich might be used to achieve the most favorable trade-off should beincluded.4-E8) V?ater data - Data used to obtain the transmissivity and storagecoefficient numbers needs to be discussed as to well location, dataIndividual well location whetherfrom each well, type of test, etc.completion was in Fruitland only. Pictured Cliffs only, etc., is neededData to back up the number offor ground water quality for USGS wells.50-55 acre ft. of run-off from the over 3000 acres is also needed.Rights-of way - an indication of alternate non lease area routesfor present pipelines, roads, and transmission lines which cross thelease should be included.9)4-FLegal conflict - the EA states that the BLM has responsibility toprohibit land uses on the oil and gas tracts that would hinder the orderlydevelopment of these resources.Since coal mining would certainly dothis, this legal conflict needs further discussion as to how this mightbe resolved.10)4-G11) Air quality - the EA should include mining emissions from mine4-H vehicles, and waste and storage pile fires. The data to support42.8 tons of particulates per year should be included.11

LETTERNO.4.CONTINUEDPage 3August 17, 1979yaste piles - no discussion is given concerning locationof mine vaste pil«s, size, toxic elements in waste, totalquantity of vaste and possible mitigating measures which mightbe required auch as back filling, revegetation, grading, etc.12)4-1*"*'[13) Mia statement III "2 - if subsidence occurs the paragraphat the top of page III-2 is not correct.kine reclamation * requirements for shaft and portal backfilling to prevent caving of these areas should be discussed.14)4-K4-LCommunity infrastructure - the coal mine on the proposed15)lease area is stated to lead to the employment of 392persons.With three persons per family this would lead toThe impact of these people1176 additional people in the area.should be examined in more detail as it would appear that theimpact may be more than is indicated in the A.The statementon p III-21, "Costs for public services would not be expectedto exceed revenues since neither population growth nor populationconcentrations in particular communities would be expected tooccur", needs careful dccomentation.Other alternatives - the alternative of building a railroadfrom the Con Paso lease and from the Navajo mine to ship surfacemined coal from these mine sites to the San Juan plant shouldbe discussed in detail.Requirements of the Navajo Tribe for thebuilding of this railway should be indicated. Even the underground mine will not meet all coal requirements for San Juan butshipments from Con Paso and Navajo could.16)4-MDewatering - more information is needed as to how the dewateringrequirements for the mine were calculated.Subsidence could causesurface or waters from the Kirtland shale to enter the mine andincrease the dewatering requirements; this should be discussed.17)4-NSincerely,A.RODRIGUEZ DirectorPAR:bp12

RESPONSES TO LETTER NO.M-AUDrill hole location and drilling data are shown inAppendix A (Beach, L. J. and Jentgen, R. W. 1978. Coaltest drilling for the San Juan Mine Extension, San JuanCounty, New Mexico. U.S. Geol. Survey Open-File Report78-960).The average thickness for each seam wasmultiplied by the number of acres on the proposedThis figure was then multiplied by 1770, thelease.number of tons per acre-foot for coal classified assubbituminous to give an estimated tonnage figure forthe two seams.,4-BThe figures were assumptions used for probable impactassessement only.If a lease is issued, theexploration application that the lessee would have tofile in conformance with Federal regulations wouldaddress the questions in your comment.4-CAs discussed on pages II-18 and 11-22, the land is usedprimarily for livestock grazing and rights-of-way.There has been no opposition to leasing indicated byrights-of-way holders, surface owners, or land users.M-DThe resource that Western will utilize for developmentof an underground mine on their existing lease wouldnot be increased if they obtained the proposed lease.Any changes from the resource commitments listed onpage II-3 resulting from different mining methods canonly be determined from a detailed mining plan based onexploration and engineering data. Similarly, coalrecovery from different seams, gas in formations,effects of subsidence, mine wastes, and reclamationwill have to be analyzed after a mining plan issubmitted. The OSM regulations provide the legalrequirements to be met before mining plan approval.M-EAppendix B summarizes the well information and U.S.Geological Survey aquifer test data supplied by Westernthat was used to obtain the transmissivity and storagecoefficient values presented in Table II-2, page 11-13.In addition, pump test data from existing observationwells at Western's adjacent surface mine were used forestimating aquifer properties of the coal formation(transmissivity, storage coefficient), as well asground water inflow to the mine (see Response 4-N)The 50-55 acre-feet runoff estimate was developed fromchannel geometry equations relating peak and annualrunoff to channel widths (Hedman, E. R. and Kastner, W.M. 1977.Streamflow characteristics related to channelgeometry in the Missouri River Basin, Jour. ResearchU.S. Geol. Survey, Vol. 5, No. 3).Although theserelationships are poor for the ephemeral channelsdraining the area, the estimate equals about 0.2 inches13

RESPONSES TO LETTER NO.4,continuedThisof runoff from the proposed lease area itself.agrees well with Soil Conservation Service maps whichindicate that there is 0.1-0.5 inches of runoff peryear in this area.4-FCopies of correspondence included in Chapter IV of thisassessment indicate satisfactory negotiations have beenreached regarding location adjustments should theybecome necessary.4-GAs indicated on Table 1-3 on page 1-10, theConservation Division of the U.S. Geological Surveywill determine priority of development between coal,and oil and gas.4-HParticulate emissions caused by mine vehicles areincluded in the total particulate emissions estimate.Gaseous emission (carbon monoxide, hydrocarbons,nitrogen oxides, and sulfur oxides) estimates from fuelcombustion are not available at this time; however,these emissions would result from the traffic estimatesshown in Appendix C, as supplied by Western.Emissions from waste and storage pile fires are notquantifiable because of their intermittent andunpredictable occurrence. The probability ofsignificant quantities of emissions from these sourceswould be low because a company mining coal would berequired

competitivele