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iderrt f ed as a need in one of the resource analyses in Chapter J. The Paonia Ranger <br />District is continuing to pursue other road decommissioning opportunities. <br />6. T1.~e proposed action cannot be categorically excluded because the GVBs are locared <br />within an Inventoried Roadless Area. <br />The proposal is being analyzed Larder this environrnental assessment. <br />7. An environmental impact statement rather than an EA should be prepared. <br />The Agency believes that gi verr ti:e scope of this project, environmental disclosure in an <br />EA is appropriate. Further, the presence of "extraordinary" circumstances does not <br />necessarily require an EIS ("Personal communication, K Capps, 7/24/01 and High <br />Country Citizen: 's Alliance vs. United States Forest Service). <br />8. The mine's continued safe operation depends on successful installation of methane <br />gas. Delays in completing [he process requirements of NEPA threaten the continued <br />operation of the mine. There is a need to sustain the viability of these coal mines. <br />The Forest Service is responding to applications for GVBs as expediently as possible, <br />while fulfilling the rrquirements of the applicable laws and regrrlatiorrs. <br />9. All proposed road building activities are per se "significant". Given planned location <br />in an inventoried roadless area. <br />The Agency believes that given the scope of this project, environmental disclosure irr an <br />EA is appropriate. f%rrrther, the presence of "extraordinary" circumstances does not <br />necessarily require an EIS (Personal communication, KCapps, 7/24/01 and High <br />Cour:try Citizen's Alliance ys. United States Forest Service). <br />10. T'he Forest Service may not approve the proposed GVBs without first securing the <br />permission of the Forest Service chief. <br />The proposed GVBs are on mt existing federal coal lease (a valid existing right), and as <br />such rare exempt jronr this requirement (36 CFR Par! 212, 7712.16). <br />11. Begin the cumulative impacts analysis on panels 16-24. <br />This erralysis considers cumulative impacts resulting from potential surface di.;turbatrce <br />from parcels l6 mid 17, and .El which are in the same longwall rlisU•ict (see Chapter _). <br />Proposed panels 13-14 are in a separate longwall district of the mime. Orr-going <br />geologic investigation regarding the presence/absence of methane irr the 18-24 region is <br />being cor:durted by ~14CC. It is not possible to estimate whether that nrea will require <br />GVBs at this time. <br />12. A.Iternative routes, including Sylvester Gulch should be considered. <br />