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Supplement Chapter 3B, and to facilitate the achievement of safe air quality working levels in the longwall panels planned for future mining. I did not approve construction of three of the proposed drill pads and associated road constmction that would occur in areas that would disturb a rmique vegetation community, where undisturbed riparian vegetation would be removed, and where the geology is unstable as described in the EA Supplement Chapter 3B. At these sites the success of reclamation is uncertain. I am granting an exception to a lease stipulation where the effects would be minor, and would not cause irreparable harm It would be irresponsible to approve an action that would cause long-term damage to surface resources on NFS lands for which [he success of mitigations being able to return the area to present conditions is uncertain. Although my decision allows an exception to the lease stipulation for riparian occupancy, it is important to understand that the approved occupancy will be along a route previously disturbed, and new disturbance in the riparian area will be nunimal. The exception to this lease stipulation afTects 1.1 acres of previously disturbed ground. A few riparian trees maybe affected by this decision, but this effect will be minimal. The mitigation measures described in the Conditions of Approval (Appendix A) for protection of riparian resources will be applied to roads and drill pads that are within the WIZ. Application of mitigation measures in the Conditions of Approval will reduce the effects to acceptable levels. No other location for these facilities is practical because of other environmental constraints and operational considerations. My decision to allow three of the six proposed drill pads to be built is consistent with previous decisions made with respect to drilling activities in Box Canyon (DN/FONSI, Proposed Coal Exploration License/Plan for Drill Sites AA, BB, CC, DD, EE, Y, Z, GG, Q and R-Alt, Paonia Ranger District, 1996). Although Box Canyon is an Inventoried Roadless Area, current Forest Plan direction allows construction of roads. This area has not been managed to protect its roadless character in the past, and consequently its roadless character has been compromised. Roadless values will not be further compromised by my decision to allow temporary road construction in Box Canyon. The GMUG Oil and Gas Leasing EIS described the Inventoried Roadless Areas on [he GMUG NFs that would be managed for future wilderness potential. The West Elk IRA was not considered eligible in that EIS, (Page III-26, FSEIS 1993 Forest Plan) and was not recommended for wilderness in the Record of Decision for the amended Forest Plan. Forest plan direction for inventoried roadless areas not recommended for wilderness allows road construction (Forest Plan, page 5-23) and encourages mineral development (Forest Plan, pages III-62 through III-65). Temporary roads for coal exploration have been approved, constructed, then reclaimed in this portion of the West Elk IRA in the project area since 1972. The reclaimed roadbed remains visible in these past road corridors.. The roadless character in this portion of the IRA has been compromised.by.repeated . construction and reclamation of roads permitted for coal exploration over the past 30 years (EA Supplement, Section 3B.6.1). Please also refer to Sections IV. 6 and 7. I understand that MDWs drilled from the land stuface are the most effective method by which to vent methane from the underground mine. I further understand that MCC has coped with methane accumulations in the past, and has been able to extract the coal, albeit at a slower rate. My decision to approve three of six proposed MDWs balances the need to efficiently and effectively vent methane from the underground mine while protecting surface resources on NFS lands consistent with the intent of the lease stipulations. I did no[ choose the no action alternative where no MD W's or roads would be built because of its potential to result in the loss of coal production and potential loss of mine employment and effects to local economies over time (EA Supplement, Section 3B 10.2). I am aware of the concern raised about effects to management indicator species, and how the Forest Services monitors and manages their habitat. My decision will not affect Forest-wide populations, trends or habitats of any MIS species (EA Supplement, Appendix C -- Response to Comments/Errata). With respect to the Box Canyon MDWs drill pads and temporary road, some resource effects could not be completely mitigated and will occur from implementation of this decision during [he five-year life of methane drainage activity in Box Canyon. Some effects will continue beyond the end of this project in 2010. I have considered-these effects and have found that none of them will be significant in either context or intensity. These include: Page 8