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COMPETITIVE COAL LEASING, page 1 <br />There appears to be a conflict between the statement that none of the 20 unsuitable citation were <br />applicable and then bringing four (actually 6) forward. <br />BACKGROUND, page 3 <br />The background implies that there were a number of existing leases and permits in the area <br />which should be able to provide additional environmental information for evaluation. <br />Map 2, page 5 <br />The map needs to be revised to show the existing New Elk mine permit area relative to the LBA <br />and to depict the extent of the proposed new permit area including the LBA and private fee coal. <br />For clarity, if there is no Forest Service or BLM surface ownership within the whole proposed <br />permit area then they should be deleted from the map legend. <br />DISCRIPTION OF PROPOSED ACTION AND ALTERNATIVES, page 6 and 7 <br />The discussion under section needs to be revised to discuss the viability or non-viability of the <br />mine without the LBA. <br />The text needs to be updated to discuss the current status of the dewatering operations since it <br />has been a year since the dewatering was started and was only projected to take three months. <br />The EA should, at a minimum, provide a baseline for the successful development of <br />environmental compliance protection measures to be implemented. It is OSM belief based upon <br />the information provided there is no assurance of success. <br />All of the discussions of methane, its release into the atmosphere and potential mitigation <br />measures should be moved to one section such as Climate Change. <br />AFFECTED ENVIRONMENT / ENVIRONMENTAL CONSEQUENCES / MITIGATION <br />Air Quality, page 8 <br />The discussion needs to be revised to describe the current ambient air quality in the region as <br />well as the proposed mine permit area including LBA. <br />Climate Change, page 11 <br />It is unclear if the methane drainage wells will be installed in advance of mining to mitigate the <br />amount of methane released into the mine as the seam is mined. Usually, there are no methane <br />gob vent wells in room and pillar mining operations. How many wells will be installed and for