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storm water management. To protect water quality from storm water runoff, including contaminated runoff from construction and operation activities, specific practices should be detailed in the EIS and their implementation defined. Perennial streams need to be protected from risk of damage by mine subsidence. In unleased areas, terms and conditions should be considered to protect non-mineral resources, including NSO lease stipulations as appropriate. For leased areas, BMPs and mitigation measures could be used to protect these resources. Particulaz focus should be given to the transition points adjacent to any anticipated stream subsidence to ascertain if the proper stream function and channel geometries will be maintained in apost-subsidence condition. 5. ,Air Quality Impacts. The protection of air quality will likely be an important issue to address in the EIS. The ' types of fuels to be used during operations should be disclosed and the relative effects on air quality and human health analyzed. VOC, NOx, SOx and PM impacts analysis will need to be ' performed. Dust particulates from construction, and ongoing operations are important concems. This analysis should also address and disclose the project's potential affect on: all criteria pollutants under the National Ambient Air Quality Standazds (NAAQS), including ozone; Prevention of Significant Deterioration (PSD) increments, visibility impairment, and air quality related values (AQRV) in the protection of any affected Class I Areas, any significant concentrations of hazazdous air pollutants, and protection of public health. The EIS should evaluate air quality impacts, and detail mitigation steps that will be taken to minimize associated impacts. The EIS should identify all relevant, reasonable mitigation for air quality impacts, even if they are outside the jurisdiction of BLM. The probability of the mitigation measures being , implemented should also be discussed. Furthermore; EPA believes that the FEIS should indicate a path to assure compliance with the PMIO NAAQS. Specifically, the FEIS should outline both regulatory and non-regulatory processes that aze in place to address air quality concerns in the project azea, as well as include all mitigation. 6. Construction The EIS should evaluate effects of any proposed road improvements, new road construction, railroad, and general right-of--way (ROVI>) construction activities on the azea. The evaluation should include increased access, travel management and enforcement aspects, as well as impact to the flora and fauna of the area. Dust particulates from construction, and ongoing operations on roadways are important concerns. The airborne dust may not only be a visual ' nuisance, but can be potentially dangerous to asthma sufferers.. Sedimentation run-off can severely impact the aquatic environment. Please include detailed specific plans for addressing dust control for the project. Items in the plan should include, though not necessarily limited to, dust suppression methods, inspection schedules, and documentation and accountability processes. Construction techniques such as 95% base compaction prior to placement of gravel on gravel roads, use of concrete or asphalt roads, culverts for water drainage, steep slope construction measures to prevent erosion, and appropriate dust control methods (such as 4 ,