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how long in advance of mining? What is the estimated drill pad size and the amount of <br />disturbance associated with the well's installation and operation? <br />Proper term is ventilation air methane (VAM). VAM typically is less than I% not 0.15 and the <br />only current VAM mitigation pilot project at an active underground mine in the United States <br />only mitigates a small fraction of VAM. <br />CULTURAL RESOURCES, page 15 <br />OSM recommends that BLM Check with the State Historic Preservation Office and local historic <br />societies with regard to prehistoric and historic sites and sites of native American cultural <br />concerns that have been previously located in the permit or surrounding areas. Then provide a <br />general description of what types of sites that were found and their numbers as background <br />information. <br />ENVIRONMENTAL JUSTICE, page 13 <br />OSM disagrees that the area has no minorities or low income populations in, or near, the <br />proposed project. This appears to be contrary to the demographics for the area according to La <br />Plata County. <br />Additionally there is no discussion of socioeconomic impacts from the reopening of the mine and <br />the creation of an estimated 170 - 200 new high paying jobs along with the associated tax <br />revenue, secondary support jobs and the impacts on local and county infrastructure. <br />FARMLANDS PRIME AND UNIQUE, page 13 <br />There is no specific information regarding the soil types and general geology of the LBA and <br />surrounding area. <br />FLOODPLAINS, WETLANDS & RAPARIAN ZONES, page 13 <br />Map 2 indicates that there are drainages in parts of the LBA that may contain riparian areas. No <br />text has been provided to discuss the impacts to these areas from the construction of the <br />ventilation shaft, methane drainage wells and subsidence. <br />INVASIVE, NON-NATIVE SPECIES, page 14 <br />While BLM may not have information regarding invasive, non-native species considering the <br />amount of methane drilling activity in the area, the existing New Elk permit and Las Animas <br />County records, the information should be available..