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<br />• <br />• <br />• Upgrading 1.3 miles of existing ATV routes <br />on NFS lands. <br />• Using and performing maintenance on <br />approximately 4.8 miles of existing National <br />Forest System Roads (NFSR); <br />Access and Road Construction. <br />This is the same as the Proposed Action except <br />there would be no road construction or <br />reconstruction or upgrades in the West Elk IRA. <br />Relative to road construction, Alternative would <br />authorize construction and use of about 19.9 miles <br />of roads necessary for these operations. About 14.1 <br />of the 19.9 miles would be new road construction, <br />4.8 miles of upgrades to existing NFSRs, and 2.0 <br />miles of ATV trail upgrades. <br />Relief from Lease Stipulation <br />Relief requested would be the same as Proposed <br />Action. <br />Activities in Inventoried Roadless Area <br />There would be no activities in IRAs under this <br />alternative. <br />Reclamation <br />Same as Proposed Action. <br />Alternatives Considered but <br />Eliminated from Detailed Study <br />Federal agencies are required by NEPA to <br />rigorously explore and objectively evaluate all <br />reasonable alternatives to the Proposed Action and <br />to briefly discuss the reasons .for eliminating any <br />alternatives that were not developed in detail (40 <br />CFR 1502.14). Public comments received in <br />response to the Proposed Action provide <br />suggestions for alternative methods for achieving <br />the purpose and need. Some of these alternatives <br />may have been outside the scope of compliance <br />with Mine Safety and Health Administration <br />requirements for methane gas management, <br />duplicative of the alternatives considered in detail, <br />or determined to be components that would cause <br />um~ecessary environmental harm. Therefore, a <br />number of alternatives were considered, but <br />dismissed from detailed consideration for reasons <br />summarized below. <br />Flaring of Methane Gas <br />Flaring of methane gas may cause mine explosions <br />due to fluctuations in the levels of methane. This is <br />an undesired condition and is not approved by <br />MSHA. <br />MSHA indicates that additional research and <br />development on this technology would have to <br />occur before MSHA would consider flaring a <br />reasonable option (personal communication B <br />Reitze, MSHA, to Liane Mattson, FS, June 2006). <br />Capture/Use of Methane and Leasing <br />of Coal. Mine Methane <br />This was not carried forward as an alternative <br />analyzed in detail because of complexities and legal <br />limitations stemming from the leasing processes <br />and regulations of two separate mineral resources, <br />uncertainty with relation to quality and quantity of <br />gas resource, and economic concerns related to <br />additional facilities do not support detailed analysis <br />in this EIS. The reasons for this include: 1) an <br />alternative to capture the gas would not satisfy the <br />specific purpose and need for the project which is to <br />ensure health and safety of the underground mine <br />and facilitate efficient recovery of leased federal <br />coal reserves, 2) such an alternative would not be <br />legal because the gas is not under lease, and 3) <br />capturing the gas was not forwarded as part of the <br />proposal made to meet mine ventilation needs to <br />satisfy MSHA requirements. A discussion of each <br />situation is given in Chapter 2. <br />Further, some of the components of the capture/use <br />of methane concept are outside of the FS control as <br />they are tied to national policy or direction. <br />Methane Drainage Wells only on <br />Currently Leased Coal Areas <br />Public comment requested that the project be <br />limited to areas within existing federal coal leases. <br />It was mentioned that a decision to allow the <br />methane drainage wells in currently unleased areas <br />would serve to improve the prospects of leasing and <br />developing unleased federal land. This alternative <br />was not considered in detail because, with the sale <br />of the Dry Fork Lease (analyzed in 2004-2005 in an <br />EIS) effective date March 1, 2007, all lands in the <br />project area have been leased. <br />Use Horizontal Boreholes or Longhole <br />Horizontal Boreholes <br />Mine Ventilation Plans including design of <br />ventilation system are approved by MSHA from <br />submittals and measurements made by MCC. <br />Deer Creek Ventilation Shaft and E Seain Methane Drainage Wells FEIS <br />S-11 <br />