2008-08-18_REVISION - C1980007 (6)

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• Relationship to Public Involvement Public comments were sought throughout this project (refer to Public Involvement Section of this document for a summary of public involvement, and Chapters 4 & 5 of the FEIS). I considered input from members of the community and other agencies in making this decision. Other Alternatives Considered The No Action Alternative (FEIS, Chapter 2, Alternative 1), and an alternative that considered no activity in the West Elk IRA (FEIS, Chapter 2, Alternative 3) were the other alternatives that were studied in detail. The No Action Alternative was the environmentally preferred alternative, because no surface disturbance would occur. A more detailed comparison of these alternatives can be found in the FEIS on Table 2-2. Under the No Action alternative, current management plans, existing approvals related to coal mining, and non-coal related activities would continue to occur or guide management of the project area (see HIS Chapter 2, Alternative 1). Under the No Action Alternative construction of the E Seam MDWs and associated access would not occur. Selection of the No Action Alternative would essentially cause the West Elk Mine to cease operations because the MDWs are required by MSHA to maintain safe levels of methane in the E Seam workings. Without an approved ventilation plan, the mining company could not receive approval from other Federal or State agencies for mining and ventilation plans. This could result in a reduced capacity for MCC to meet its coal contractual obligations resulting in a decreased ability to recover currently leased federal coal reserves which would have expanded negative effects on local economy. Selection of this alternative would not meet the purpose and need, and would be inconsistent with rights granted by the coal lease, the Forest Plan, and national policy. Under Alternative 3-No Activity in Roadless, no surface activity would be permitted in the West Elk IRA; the remainder of the proposed activities would be the same as the Proposed Action. In this alternative, the number of MDW locations would be reduced to 135, and overall road construction would reduce to approximately 14 miles. This limited access would result in reduced capacity to extract about 10 million tons of leased coal reserves, and shorten mine life by about 2 years, and could have attendant negative effects on local economy. It could also result in failure to meet MSHA ventilation needs. Selection of this alternative would not fully meet the purpose and need, and would be inconsistent with rights granted by the federal coal leases, the Forest Plan, and national policy as activity in IRAs is permitted as it fits under exceptions to the 2001 RACR. Public Involvement The Notice of Intent (NOI) to prepare an environmental impact statement (EIS) for the Deer Creek Shaft and E Seam Methane Drainage Wells was published in the Federal Register on September 18, 2006. The NOI asked for public comment on the proposal from September 18 through November 2, 2006. In addition, as part of the public involvement process, the agency published legal notices in the Grand Junction Dally Sentinel and Delta County Independent as papers of record and sent approximately 35 scoping letters to required agencies, Tribes, and interested parties list (project file). The NOI was posted on the GMUG's public planning webpage, and the project was included on the GMUG's Quarterly Schedule of Proposed Actions. GMUG personnel briefed the North Fork Coal Working Group at its quarterly meetings on October 10, 2006, January 16, April 10, and July 10, 2007. An additional article was published in the Delta County Independent on November 1, 2006 written by an unknown source. Five comments were received during initial scoping. Using the comments from internal scoping, the public, other agencies, and associations and the interdisciplinary team, a list of issues was developed (EIS, Chapter 1, Issues). 10