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alternatives.") Similarly here, the Forest Service muse analyze alternatives that would requiring <br />flaing or capture of methane even if "some of the components of the capture/use of methane <br />concept are outside of the FS control." <br />D. The FEIS Failed To Include "A Reasonably Complete Discussion" Of <br />Mitigation Measures. <br />NEPA requires that agencies mitigate the adverse environmental impacts of their actions. <br />Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 351-52 (1989); Holy Cross <br />Wilderness Fund v. Madigan, 960 F.2d 1515, 1522 (10th Cir. 1992). Mitigation measures are <br />also required by NEPA's implementing regulations, 40 C.F.R. §§ 1502.14(f), 1502.16(h). The <br />Tenth Circuit has held that an agency's analysis of mitigation measures "must be `reasonably <br />complete' in order to `properly evaluate the severity of the adverse effects' of a proposed project <br />prior to making a final decision." Colo. Envt'l Coal, v. Dombeck, 185 F.3d 1162, 1 173 (10`' Cir. <br />1999) (quoting Robertson, 490 U.S. at 352). A "perfunctory description" of mitigation <br />measures, without "supporting analytical data" analyzing their efficacy, is inadequate to satisfy <br />NEPA's requirements that an agency take a "hard look" at possible mitigating measures. <br />Neighbors of Cuddy Mountain v. U.S. Forest Serv., 137 F.3d 1372, 1380 (9" Cir. 1998). <br />Moreover, in its final decision documents, an agency must "[s]tate whether all practicable means <br />to avoid or minimize environmental harm from the alternative selected have been adopted, and if <br />not, why they were not." 40 C.F.R. § 1505.2(c). <br />The Project FEIS does not contain the required "reasonably complete discussion" of <br />possible steps that could be taken to mitigate adverse environmental consequences of the <br />additional release of methane. See Robertson, 490 U.S. at 352. A "reasonableness standard <br />applies both to which alternatives the agency discusses and the extent to which it discusses <br />them." Utahns for Better Transp., 305 F.3d at 1166. The Project FEIS stated that either flaring <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 33