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Environmental Assessment <br /> 2.2 No Action <br /> The BLM NEPA Handbook(USDI/BLM 2008) states that for EAs on externally initiated Proposed <br /> Actions,the No Action Alternative is generally to reject the proposal or deny the license. This option is <br /> provided in 40 CFR 1502.14. The No Action Alternative provides a useful baseline for comparison of <br /> environmental effects (including cumulative effects) and demonstrates the consequences of not meeting <br /> the need for the action. <br /> Under the No Action Alternative,the coal lease modification would not be approved. Thus, federal coal <br /> reserves within the four tracts being applied for would not be recovered by GCC and approximately 4.66 <br /> million tons of recoverable coal would not be mined. <br /> Coal production at the King II Mine would cease once coal reserves under existing leases were mined and <br /> reclamation activities would commence. Based on GCC and BLM estimates,reserves would be depleted <br /> prior to 2019; dependent upon how GCC staggered production as it began mine closure. Under the No <br /> Action Alternative,there would be no new surface disturbance, removal of coal, or other impacts <br /> associated with the activities described under the Proposed Action. Under this scenario, GCC would <br /> likely request renegotiation of the RIA with LPC as the currently required improvements could not be <br /> capitalized without the coal production authorized in the RIA. For this analysis, it is estimated that road <br /> improvements would be completed through Phase 3 (November 2019). <br /> 2.3 Alternatives Considered but Eliminated from Detailed Study <br /> If an alternative is considered during the EA process but the agency decides not to analyze the alternative <br /> in detail,the agency must identify those alternatives and briefly explain why they were eliminated from <br /> detailed analysis (40 CFR 1502.14).An action alternative may be eliminated from detailed analysis if <br /> ■ it is ineffective (does not respond to the purpose and need); <br /> ■ it is technically or economically infeasible (consider whether implementation of the alternative is <br /> likely given past and current practice and technology); <br /> ■ it is inconsistent with the basic policy objectives for the management of the area(such as,not in <br /> conformance with the land use plan); <br /> ■ its implementation is remote or speculative; <br /> ■ it is substantially similar in design to an alternative that is analyzed; and, <br /> ■ it would have substantially similar effects to an alternative that is analyzed. <br /> Several alternatives to the proposed lease modification were considered,including alternative lease tracts <br /> as well as alternative coal removal and transport methods to minimize the impacts for efficient coal <br /> resource recovery. <br /> DOI-BLM-CO-S010-2011-0074-EA <br /> September 2017 <br /> -50- <br />