2008-03-10_GENERAL DOCUMENTS - C1980007

Home Browse Search

of Proposed Action in Chapter 2 of the FEIS for further discussion). Additionally, as a measure of comparison, Alternative 3 -No Activity in (Inventoried) Roadless (Area) which did not include any drill locations or road construction in the IRA was added to the FEIS. Venting methane (a greenhouse gas) was a concern for various reasons including effects on air quality, desire for other options to venting methane such as capture and use or flaring of methane, and contribution of methane release on climate change. Methane release effects on air quality are analyzed in the Air Quality section, Chapter 3 of FEIS. Methane volume estimated to be released was, however, reported at the State level for fossil fuel combustion where a level of change (or significance) could be determined. It should be noted that future methane release is estimated to be a reduction by 50-60% of what is currently being released by mine operations at the West Elk Mine based on the differences in coal seams. Further, no air quality regulations or standards governing methane have been promulgated at this time. The situation related to capture and use of the methane is addressed in Altematives Considered but Eliminated from Detailed Study (FEIS, Chapter 2), and in the Response to Comments (Chapter 5 of the FEIS). Additional information is given in responses to EPA's August 7, 20071etter (Project File). The situation related to flaring methane is addressed in Alternatives Considered but Eliminated from Detailed Study (FEIS, Chapter 2), Response to Comments (Chapter 5 of the FEIS), and Appendix D of this document (Supplemental Information Report: Flaring of Methane Gas). Some respondents wished to have the contributions of the project on climate change analyzed in detail; however, due to lack of reasonably available modeling, there is no way to predict global-scale effects from this project. Therefore, global warming was considered anon-significant issue for this analysis and outside the scope of analysis (FEIS, Chapter 2 and Response to EPA's August 7, 2007 Letter, project file). With respect to road use for construction equipment, the FEIS discloses the effects of construction traffic in Chapter 3, Transportation. Oversize/over-length vehicles such as the drill rig and semi-trucks (large equipment transport) would access from the west through the town of Paonia, then via Minnesota Creek Road (Delta County/Gunnison County Road 710), and NFSRs 710 and 711. The estimated traffic associated with use of county roads for oversized vehicles is estimated at 5 round trips per mar until project completion. County road use was addressed and resolved between the company and the county through a maintenance agreement process. Other issues raised with respect to E Sewn MDWs and associated access of these activities are presented in the FEIS (Chapters 1 and 3). For all disciplines, Best Management Practices and Design Criteria will be implemented to minimize effects. Benefits will also occur from implementation of the E Seam MDW Project. By allowing the E Seam MDWs and associated access, ]eased Federal coal reserves will continue to be mined and made available to supply energy needs of the country. This will continue to provide economic benefit to the surrounding communities for the next 12 years. Factors Other Than Environmental Effects Considered In Making the Decision The purpose and need of this project is to protect public health and safety, to prevent loss of leased federal coal resources, and to facilitate safe and efficient production of compliant and super compliant coal reserves. The purpose and need also support the rights of the Federal Coal Lessee to construct structures which may be necessary to exercise lease rights (EIS, Chapter ]Purpose and Need). My decision supports the Purpose and Need for this project.