2008-03-21_PERMIT FILE - C1980007 (5)

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Summary prescription 3A for non-motorized recreation emphasis. The IRA lands within the project a,-ea 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 Pian 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 Record of Decision (ROD) states that the portion of the West Elk IRA west of Coal Creek has existing coal leases, and that coal exploration activities and 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 the 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. 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 alternative was considered but not analyzed given the 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. Accessing Coal in the 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. Given that the Dry Fork LBA tract is immediately adjacent to the West Elk Mine, it is unlikely that any other mining firms besides MCC would be able to economically extract this resource. This alternative was considered but not analyzed given current reasonable expectations that the coal in the lease tract would be extracted by MCC. If a successful lessee (besides Ark Land) decides that a separate mining operation should be completed, it would be necessary to undertake additional environmental analysis to determine the surface impacts, which would be different than the impacts if the coal is removed through the existing underground workings and surface facilities of the West Elk Mine. Further, the most likely scenario if another company obtained the Dry Fork LBA tract, would be that it would subcontract MCC to mine it from the existing mine, rather than build new facilities (BLM 2004). COMPARISON OF ALTERNATIVES Meeting the Purpose and Need and Forest Plan Standards Alternative A does not meet the stated purpose and need. Alternatives B and C do meet the stated purpose and need. r1 • r? . All the alternatives are consistent with the GMUG Forest Plan standards and guidelines. S-s Dry Fork Lease-By-Application FENS