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2 <br />outside the scope of compliance with Mine <br />Safety and Health Administration requirements <br />for methane gas management, duplicative of <br />the alternatives considered in detail, or <br />determined to be components that would cause <br />unnecessary environmental harm. Therefore, a <br />number of alternatives were considered, but <br />dismissed from detailed consideration for <br />reasons summarized below. <br />Flaring of Methane Gas <br />Flaring of methane gas may cause mine <br />explosions due to fluctuations in the levels of <br />methane. This is an undesired condition and is <br />not approved by MSHA. <br />Flaring of methane gas was brought forward as <br />a way to mitigate venting of methane, a potent <br />green house gas, to the atmosphere. It is <br />acknowledged that flaring : may be used to <br />reduce green house gas emissions; however, the <br />FS understands from the MSHA District Office <br />in Lakewood, CO that this activity is not <br />approved by MSHA due to the potential safety <br />hazard to the underground mine. MSHA <br />indicates that additional research and <br />development on this technology would have to <br />occur before MSHA would consider flaring a <br />reasonable option (personal communication B <br />Reitze, MSHA, to Liane Mattson, FS, June <br />2006). <br />Capture/Use of Methane and Leasing <br />of Coal Mine Methane. <br />Several comments were received during project <br />scoping and on the Draft EIS related to <br />capturing the natural gas encountered during <br />mining operations, and putting it to beneficial <br />use rather than allowing it to vent as a way to <br />avoid wasting the gas resource and to mitigate <br />potential contribution to greenhouse gas <br />emissions. It was also suggested that this <br />concept be analyzed as an alternative to the <br />Proposed Action. This was not carried forward <br />as an alternative analyzed in detail because of <br />complexities and legal limitations stemming <br />from the leasing processes and regulations of <br />two separate mineral resources, uncertainty <br />with relation to quality and quantity of gas <br />resource, and economic concerns related to <br />additional facilities do not support detailed <br />analysis in this EIS. The reasons for this <br />include: 1) an alternative to capture the gas <br />would not satisfy the specific purpose and need <br />for the project which is to ensure health and <br />safety of the underground mine and facilitate <br />efficient recovery of leased federal coal <br />reserves, 2) such an alternative would not be <br />legal because the gas is not under lease, and 3) <br />capturing the gas was not forwarded as part of <br />the proposal made to meet mine ventilation <br />needs to satisfy MSHA requirements. A <br />discussion of each situation is given below. <br />Further, some of the components of the <br />capture/use of methane concept are outside of <br />the FS control as they are tied to national policy <br />or direction. <br />Mineral Leasing Situation <br />As coal, and oil and gas, resources are managed <br />under separate programs by the BLM, and fall <br />under differing regulations (43 CFR 3400 for <br />coal, and 43 CFR 3100 for oil and gas), they <br />have specific management needs. For example, <br />the federal coal lease grants the lessee the <br />exclusive right and privilege to drill for, mine, <br />extract, remove or other wise process and <br />dispose of the coal deposits in the lease (see <br />also Purpose and Need), the coal lease does not <br />grant the right to the coal lessee to capture gas <br />released incident to mining. Further, the coal <br />lease reserves the right of the Lessor (BLM) to <br />lease other mineral deposits contained on the <br />leased coal lands including other leaseable <br />minerals (BLM Form 3400-12, Section 7), <br />which includes oil and gas. <br />The natural gas occurring in the coal seams and <br />adjacent strata that could be encountered while <br />mining the E seam coal reserves is considered a <br />federal resource that is managed by BLM. The <br />basic premise related to capturing the coal mine <br />natural gas is that, as a federal resource, the gas <br />must first be duly under lease in order for <br />capture and use to occur. According to BLM, <br />absent an oil and gas lease, the natural gas <br />encountered as a byproduct of the mining <br />cannot be captured and put to beneficial use, as <br />44 Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS