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climatically important and that avoiding methane emissions not only reduce climate warming but <br />also have benefits for air quality." EPA Comments on Project at 7. Appellants also provided a <br />number of sources of information from which the Forest Service could credibly analyze and <br />assess the global warming impacts related to the Project, including sources from the Department <br />of Energy. These reports are available online at http://www.ipcc.ch/index. him. The <br />Intergovernmental Panel on Climate Change's latest Fourth Assessment Report, Summary for <br />Policymakers, which synthesizes similar information, is also attached as Exh. 5. <br />Finally, rather than discussing whether general theoretical approaches or research <br />methods might inform an evaluation of the effects of the methane drainage, the FEIS simply <br />ignored this final factor required by § 1502.22(b). The Forest Service's failure to adhere to the <br />requirements of 40 C.F.R. § 1502.22(b) requires that its decision be reversed. <br />C. The FEIS Failed To Analyze A Reasonable Alternatives That Reduced The <br />Potential Greenhouse Gas Emissions Of The Project. <br />NEPA requires agencies to "study, develop, and describe appropriate alternatives to <br />recommended courses of action in any proposal which involves unresolved conflicts concerning <br />alternatives uses of available resources." 42 U.S.C. § 4332(2)(E). To achieve these ends, an EIS <br />must "[r]igorously explore and objectively evaluate all reasonable alternatives." 40 C.F.R. <br />§ 1502.14; Utahns for Better Transp., 305 F.3d at 1 166 (emphasis added). This alternatives <br />analysis is "the heart of the [EIS]." 40 C.F.R. § 1502.14. In this case, the Forest Service failed <br />to rigorously explore and objectively evaluate alternatives that would reduce or eliminate <br />methane emissions via flaring or capture.6 In failing to evaluate such alternatives, the Forest <br />b At least one coal mine expert, upon reviewing Forest Service NEPA and decision <br />documents, concluded that the agency clearly failed to analyze reasonable alternatives including <br />flaring and capture. See J. Hempel, EEI Geophysical, "Preliminary Assessment of the Feasibility <br />of Capturing and Using Coal Bed Methane from the "E" Seam in the West Elk Coal Mine," <br />Apr. 25, 2008 ("EEI Geophysical Report") attached as Exh. 6. <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 11