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statement that such information is incomplete or unavailable; (2) a statement of the relevance of <br />the incomplete or unavailable information; (3) a summary of relevant existing credible scientific <br />evidence; and (4) the agency's evaluation of such impacts based upon theoretical approaches or <br />research methods generally accepted in the scientific community. "The duty of the agency is to <br />use theories or research methods to assess the impacts of the proposed action in the absence of an <br />answer to [a central] question." Cabinet Resource Group v. United States Fish and Wildlife <br />Serv., 465 F. Supp. 2d 1067, 1 100 (D. Mont. 2006). Here, the Project FEIS utterly failed to <br />follow these requirements. <br />The Project FEIS stated that "it is not possible to estimate or calculate the effect that <br />methane emissions from this project would have on global warming." Project FF.,IS at 60. <br />Although the Forest Service claimed that "[t]here are no models that can calculate the amount of <br />global warming (if any) that would occur due to this alternative, nor is there scientific research <br />that can be used to estimate the effects," Project FEIS at 61, the Forest Service acknowledged in <br />response to comments from the EPA that, "models that assess atmospheric [greenhouse gas] <br />loading on a global scale do exist." See "For Deer Creek Shaft/E Seam project file: Responses to <br />August 7, 2007 EPA letter" at fax page 18 of 32, attached at Exh. 4.5 The Forest Service's claim <br />that there is no "scientific research that can be used to estimate the effects [on global warming]" <br />is contradicted by the agency's own statements. Project FEIS at 61. <br />Furthermore, instead of providing a summary of relevant existing credible scientific <br />evidence, the Project FEIS stated that "[t]here is no credible scientific evidence with which to <br />evaluate the potential impacts related to methane drainage associated with this project." Id. Yet <br />as the EPA stated in its comments, "[n]umerous studies have shown increases in methane are <br />5 This response to EPA's comments contained in the Forest Service's project file is more <br />detailed than, and in some cases differs from, the responses to comments contained in the FEIS. <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 10