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cttoii: _ :`P~ a of •, ~E~-r ~ ` _. __ .~~ ~ - <br />Table 5-1 184 -192 The notation with the listing of Rocky Mountain Clean Air <br />Action in the left hand column of the table indicates their <br />comment letter was received after the comment period, and <br />that the organization had no appeal standing was made in <br />error. Their comment letter was duly postmarked by the <br />close :of the comment period (project file); therefore, this <br />nr¢ani~ation retains eligibility under FS appeal regulations. <br />Reasons for the Decision <br />Applicable Laws Regulations and Policy <br />The selected alternative meets requirements under the Mineral Leasing Act, as amended, the National <br />Environmental Policy Act, National Forest Management Act, Surface Mining Control and Reclamation <br />Act, the Colorado Surface Coal Mining Reclamation Act, and other applicable laws and regulations (refer <br />to the Findings Required by Other Laws and Regulations section of this document and FEIS, Chapter 1, <br />Authorizing Actions). <br />How Issues Were Considered <br />The key and non-key issues identified for the project are shown in Chapter 1 of the FEIS. Primary issues <br />of concern related specifically to E Seam MDWs and associated access included effects of road <br />construction in the West Elk Inventoried Roadless Areas (IRA), effects of methane venting on air quality <br />and climate change, and heavy traffic use on county roads,. To address these, the Forest Service <br />considered alternatives (both analyzed in detail and Alternatives Considered but Eliminated from Detailed <br />Study) described in Chapter 2 of the FEIS. <br />Concerns were raised on the project with respect to activities occurring in the West Elk Inventoried. <br />Roadless Area (IRA). In response to concerns from the public, the FEIS analyzed the effects of MDW <br />locations and road construction in the IRA under Alternative 2. Only temporary roads that could be <br />authorized using Exception 7 to the Roadless Area Conservation Rule of 2001 (RACR) were considered <br />in the FEIS (see Summary Description of the Proposed Action Activity In Inventoried Roadless Areas, <br />Roadless Area Conservation Rule of 2001, Federal Coal Leases Sections in Chapter 1 and Development <br />of Proposed Action in Chapter 2 of the FEIS for further discussion). Additionally, as a measure of <br />comparison, Alternative 3 No Activity in (Inventoried) Roadless (Area) which did not include any drill <br />locations or road construction in the IRA was added to the FEIS. <br />Venting methane (a greenhouse gas) was a concern for various reasons including effects on air quality, <br />desire for capture and use of the methane, and contribution of methane release on climate change. <br />Methane release effects on air quality are analyzed in the Air Quality section, Chapter 3 of FEIS. Methane <br />volume estimated to be released was, however, reported at the State level for fossil fuel combustion where <br />a level of change (or significance) could be determined. It should be noted that future methane release is <br />estimated to be a reduction by 50-60% of what is currently being released by mine operations at the West <br />Elk Mine based on the differences in coal seams. Further, no air quality regulations or standards <br />governing methane have been promulgated at this time. <br />The situation related to capture and use of the methane is addressed in Alternatives Considered but <br />Eliminated from Detailed Study (FEIS, Chapter 2), and in the Response to Comments (Chapter 5 of the <br />FEIS). Additional information is given in responses to EPA's August 7, 2007 letter (Project File). <br />7 <br />