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Chapter 2 and it does not meet the purpose and need of the Proposed Action. 2.7.3 No Mining Under the Inventoried Roadless Area A comment suggested an alternative be considered that halted the mining at the boundary of the IRA. About one-third of the Dry Fork lease tract Iles within the West Elk IRA. In 1972, the West EIkIRA was identified. The IRA included approximately 230,000 acres adjacent to and surrounding the north, west, and south sides of the West Elk Wilderness (established in 1964). The 1979 Roadless Area and Review Evahiation (RARE 11) recommendation for the West Elk IRA included a wilderness recommendation for over half of the IRA and mzdtiple use management recommendations for the remaining acres. As a result, 133,000 acres of the West Elk IRA was added to the West Elk Wilderness in the Colorado Wilderness Act of 1980 (PL 96-560J. The remaining portion, 98,281 acres, was not recommended or selected for wilderness then or in the Colorado Wilderness Act of 1993. The 1983 Land and Resource Management Plan (LRMP) and the 1991 Amended LRMP recognized that the remaining portion of the West Elk IRA had little suitability for wilderness designation. Part of the IRA near Lamborn Peak, (southwest of the project area) was allocated to management prescription 3A for non-motorized recreation emphasis. The IRA lands within the project area were allocated to management prescriptions SB and 6A, wildlife winter range, and livestock management. Construction of roads and use of motorized recreation vehicles is permitted in these prescriptions and within the project area. The West Elk IRA was not identified as a "Further Planning Area" for wilderness consideration in the Forest Plan Record of Decision. In 1993, a significant amendment to the Forest Plan was approved for oil and gas leasing. The Oil and Gas EIS included an updated roadless character and wilderness values analysis for the portion of the West Elk IRA that was not designated as wilderness in 1980. The associated ROD states that the portion of the West Elk IRA west of Coal Creek has existing coal leases, and that coal exploration activities and Alternatives existing roads have compromised roadless character values. The ROD made this area available for oil and gas leasing with controlled use stipulations for most of the area. No surface occupancy stipulations were established for steep slopes, high geological hazards, and riparian areas. The roadless character of the portion of the West Elk IRA in which the Dry Fork LBA lies was re- evaluated in the 2002 Environmental Assessment (EA) for Methane Drainage, which also showed that the roadless character had been compromised. Any post-lease road construction or reconstruction on [he LBA tract would be subject to rule making and directives relative to IRAs in effect at the time post-lease activities are proposed. The GMUG Forest Plan allows for road building in this area. The current Interim Directive for Roadless Area management (7700-2003-2) does not prohibit leasing in IRAs. 2.7.4 Room and Pillar Mining (No Longwall Mining) of Dry Fork LBA Tract The impacts of room and pillar mining were not assessed for the Dry Fork LBA tract. This altemative was considered but not analyzed given [he current reasonable expectation that coal in the lease would be recovered by Longwall mining techniques. If a successful lessee decides that mining should be completed solely by room and pillar methods, it might be necessary to undertake additional environmental analysis to determine mining impacts, especially the subsidence potential, which would be different than Longwall induced subsidence. BLM reports that room and pillar mining is not a viable option for competitive economic recovery of the coal. 2.7.5 Accessing Coal in Dry Fork LBA Tract Through Separate Surface Facilities Accessing the Federal coal reserves in the Dry Fork LBA tract through portal and coal handling facilities separate from the MCC facilities would not be feasible, as the coal does not outcrop in the area. Dry Fork Lease-lay-Application FEIS 2-7