2009-12-21_GENERAL DOCUMENTS - C1981012

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I. MIGRATORY BIRDS, page 14 - 17 It is a standard when discussing flora and fauna to provide the common name as well as the scientific name. Environmental Consequences/Mitigation, page 18 The statement, "Numerous cultural resource inventories have been conducted in the county, ..." conflicts with previous statements made under the Cultural Resources criterion. THREATENED, ENDANGERED, AND SENSITIVE SPECIES, page 18 There is no discussion of the threatened, endangered or sensitive species that occur, or could potentially occur, on or adjacent to the LBA. The U.S. Fish && Wildlife Service currently lists three threatened or endangered and three candidate species that occur in Las Animas county. Lacking surveys or definitive habitat descriptions it is unclear whether or not these species could occur on the LBA or adjacent area. WATER QUALITY, SURFACE AND GROUND, page 19 - 20 There is no discussion to characterize the current surface and groundwater quality and quality for the proposed new mining area. The discussion should include the anticipated impacts of mine water discharges on both surface and groundwater resources. VEGETATION, page 22 The text should reference the discussion previously presented for migratory birds. WILDLIFE, AQUITIC, page 22 BLM should provide text to discuss this criterion from other available sources. FONSI The FONSI will likely need revision based upon reconsideration / changes in the EA. Appendix A. Criterion 3 BLM has misinterpreted the Federal regulations under 30 CFR 761.11. These regulations relate to surface coal mining operations and not underground mining operations. The Federal regulations under 30 CFR 784.20 permits the undermining of manmade surface features and resources in accordance with an approved subsidence control plan. A discussion of potential subsidence impacts should be made in the main body of the EA.