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12. Management, Mitigation and Monitoring. <br />With projects such as the Red Cliff Coal Mine, there aze many activities requiring <br />management, mitigation, and monitoring of construction and operational project impacts, as well <br />as reclamation status and effectiveness. Proper BMP and other mitigation measures <br />implementation and maintenance aze very important, and various impacts can be minimized or <br />potentially eliminated if these mitigation measures aze properly implemented. Details should be <br />provided for accomplishing these activities in the EIS. Also, it is important to specifically <br />designate what entity (e.g., BLM, the proponents, resource organizations, or some combination) <br />will be in chazge of which activities, and which will have specific enforceable accountability. In <br />addition, the BMPs, mitigation measures and other related activities require inspection, <br />documentation and record keeping. A "paper" documentation trail must exist to determine what <br />was monitored, inspected, maintained, and completed. All :nanagement, mitigation, and <br />monitoring should be verifiable, and anagency/entity needs to beheld accountable for <br />performance oversight, throughout the entire project construction and operating life. Please <br />provide details on the issues discussed above in the EIS, preferably in a separate monitoring plan. <br />