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He indicates that the coal companies, the Environmental Protection Agency, and several private <br />consultants are investigating the feasibility of capture for the North Fork mines. Id. He also <br />states that the GMUG National Forest has entered into a memorandum of understanding with a <br />local utility that includes analyzing the feasibility of generating electricity from methane. Id. He <br />reasserts that the GMUG National Forest forwarded gas lease parcels to BLM. Id. Fie concludes <br />by stating that "[f]inding just the right solution for utilization of methane, thereby reducing <br />greenhouse gas emissions ... is on the nearby horizon." Id. Again, if capturing methane is "on <br />the nearby horizon," and something the Forest Service is "working diligently" to achieve, it does <br />not appear to be so complex an alternative that it cannot be analyzed as required by NEPA's <br />mandate that the agency consider "all reasonable alternatives." <br />Third, the Forest Service's statement that jurisdictional and legal complexities may <br />render capture difficult to achieve ignores the fact that the mine may be able to capture and use <br />the gas without a Federal oil and gas lease. The Forest Service apparently must consult with the <br />BLM and other appropriate agencies to determine if capturing is beneficial to the government. <br />On the second page of their responses to the EPA August 7, 2007 comment letter, the USFS <br />states: <br />First the basal factor affecting this likelihood is that the gas reserves (which are a <br />federally-managed resource) are not under lease at this time. Until such time that <br />the gas is under lease, its capture and use would be illegal. The EPAs [sic] <br />CMOP program acknowledges that "if no lease is held for the gas, it may only be <br />vented to the atmosphere for safety purposes as set out by... [M]SHA.["] USEPA, <br />Coalbed Methane Extra, Fall 2007). <br />See Exh. 4 at fax page 11 of 32. Here, the Forest Service is selectively quoting from a broader <br />paragraph in a manner that eliminates key information indicating that methane capture need not <br />require a lease: <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 25