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• Upgrading 1.3 miles of existing ATV routes an undesired condition and is not approved by on NFS lands. MSHA. I~ U • Using and performing maintenance on approximately 4.8 miles of existing National Forest System Roads (NFSR); Access and Road Construction This is the same as the Proposed Action except there would be no road construction or reconstruction or upgrades in the West Elk IRA. Relative to road construction, Altemative would authorize construction and use of about 19.9 miles of roads necessary for these operations. About 14.1 of the 19.9 miles would be new road construction, 4.8 miles of upgrades to existing NFSRs, and 2.0 miles of ATV trail upgrades. Relief from Lease Stipulation Relief requested would be the same as Proposed Action. Activities in Inventoried Roadless Area There would be no activities in IRAs under this altemative. Reclamation Same as Proposed Action. Alternatives Considered but Eliminated from Detailed Study Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives to the Proposed Action and to briefly discuss the reasons for eliminating any altematives that were not developed in detail (40 CFR 1502.14). Public comments received in response to the Proposed Action provide suggestions for altemative methods for achieving the purpose and need. Some of these altematives may have been outside the scope of compliance with Mine Safety and Health Administration requirements for methane gas management, duplicative of the altematives considered in detail, or determined to be components that would cause unnecessary environmental harm. Therefore, a number of alternatives were considered, but dismissed from detailed consideration for reasons summarized below. Flaring of Methane Gas Flazing of methane gas may cause mine explosions due to fluctuations in the levels of methane. This is MSHA indicates that additional reseazch and development on this technology would have to occur before MSHA would consider flaring a reasonable option (personal communication B Reitze, MSHA, to Liane Mattson, FS, June 2006). Capture/Use of Methane and Leasing of Coal Mine Methane This was not carried forward as an alternative analyzed in detail because of complexities and legal limitations stemming from the leasing processes and regulations of two separate mineral resources, uncertainty with relation to quality and quantity of gas resource, and economic concerns related to additional facilities do not support detailed analysis in this EIS. The reasons for this include: 1) an alternative to capture the gas would not satisfy the specific purpose and need for the project which is to ensure health and safety of the underground mine and facilitate efficient recovery of leased federal coal reserves, 2) such an alternative would not be legal because the gas is not under lease, and 3) capturing the gas was not forwazded as part of the proposal made to meet mine ventilation needs to satisfy MSHA requirements. A discussion of each situation is given in Chapter 2. Further, some of the components of the capture/use of methane concept are outside of the FS control as they are tied to national policy or direction. Methane Drainage Wells only on Currently Leased Coal Areas Public comment requested that the project be limited to azeas within existing federal coal leases. It was mentioned that a decision to allow the methane drainage wells in currently unleased areas would serve to improve the prospects of leasing and developing unleased federal land. This altemative was not considered in detail because, with the sale of the Dry Fork Lease (analyzed in 2004-2005 in an EIS) effective date March 1, 2007, all lands in the project area have been leased. Use Horizontal Boreholes or Longhole Horizontal Boreholes Mine Ventilation Plans including design of ventilation system are approved by MSHA from submittals and measurements made by MCC. Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS S-11