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Yi. <br />Although the Forest Service responsibility within the federal coal program relates to use of the surface <br />lands, I acknowledge that implementation of this project could result in the release of about 7 million <br />cubic feet per day of methane. Further, I understand other federal agencies and private interests are <br />concerned about release of methane from the mine into the atmosphere, and I share the goal of having the <br />gas resources under lease to facilitate mitigating' the release of methane by some mechanism should it be <br />feasible. Up to this point, mitigating released methane by capture and use has not been possible because <br />the gas resources (which are federally managed) are not under lease, and therefore implementing this type <br />of mitigation can not occur (FEIS, pp..44 to 46, Chapter,5 and responses to EPA letter in project file). To <br />this end, I conunitted that the GMUG would complete the needed work to forward consent to BLM <br />leasing the gas lease parcels that are coincident with the Federal coal leases in the project area. However, <br />due to the presence of IRA in the project area, not all of the lands nominated for gas lease could be <br />brought forward for lease as such would be inconsistent with the RACR as reinstated by the 9`'' District <br />Court for the Northern District of California. As of the date of this ROD, the GMUG had forwarded all <br />lands nominated for gas lease in the project area outside of the IRA to the Rocky Mountain Regional <br />Office per standard procedure. By completing this work, the first critical step to affording potential <br />methane release mitigation is underway. On a related note, interested parties also expressed the desire to <br />condition the gas leases so to be complimentary with on-going coal operations. The BLM Colorado State <br />office and the Rocky Mountain Regional Office are currently reviewing this issue. It is currently unknown <br />when BLM might offer these particular nominations on an oil and gas lease sale. <br />With respect to reducing greenhouse gas emissions by flaring-the methane, the GMUG investigated this <br />option with the Mining Safety and Health Administration (MSHA). MSHA forwarded that they would <br />not approve flaring because there are too many unknowns, no evaluations and no actual testing for this <br />technology in a no-risk mine type situation that would demonstrate its safety (see Appendix D of this <br />document). As the Forest Service role in the federal coal program is limited to surface use, it has no <br />authority to require flaring. <br />Relationship to Public Involvement <br />Public comments were sought throughout this project (refer to Public Involvement Section of this <br />document for a summary of public involvement, and Chapters 4 & 5 of the FEIS). <br />I considered input from members of the community and other agencies in making this decision. <br />Other Alternatives Considered <br />The No Action Alternative (FEIS, Chapter 2, Alternative 1), and an alternative that considered no activity <br />in the West Elk IRA (FEIS, Chapter 2, Alternative 3) were the other alternatives that were studied in <br />detail. The No Action Alternative was the environmentally preferred alternative, because no surface <br />disturbance would occur. A more detailed comparison of these alternatives can be found in the FEIS on <br />Table 2-2. <br />Under the No Action alternative, current management plans, existing approvals related to coal mining, <br />and non-coal related activities would continue to occur. or guide management of the project area (see FEIS <br />Chapter 2, Alternative 1_). Under the No Action Alternative construction of the E Seam MDWs and <br />associated access would not occur. Selection of the No Action Alternative would essentially cause the <br />West Elk Mine to cease operations because the MDWs are required by MSHA to maintain safe levels of <br />methane in the E Seam workings. Without an approved ventilation plan, the trrining company could not <br />receive approval from other Federal or State agencies for mining and ventilation plans. This could result <br />' Methods of mitigating methane release to reduce greenhouse gas emissions and current understanding of <br />feasibility of them are dicussed in the FEIS Chapter 2 and 5, in the GMUG response to an EPA letter in <br />the project file and Appendix D of this document. <br />10 <br />