2008-06-09_PERMIT FILE - C1980007 (5)

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Alternatives Considered but Eliminated from Detailed • <`.• • it would be illegal to do so without an oil and gas lease. Having the gas under lease is a desirable condition for the FS and one the agency has pursued with BLM (project file). The FS and BLM have discussed placing the gas under lease, and have explored the gas leasing process, including opportunity for non- competitive leasing (project file). BLM, in consultation with their solicitors have assessed that the agency has no authority to offer gas leases non-competitively. Therefore, any gas leases would have to be let through BLMs established competitive leasing process. Lands in the project area were identified in the GMUG's 1993 Oil and Gas Leasing EIS as having high potential for oil and gas to occur, and were made available and authorized for oil and gas leasing in the Record of Decision. Gas lease nominations were made for the project area in approximately 2002; however, the FS has been unable to act upon them because changes in various legal requirements have prevented processing them for sale. First, the listing of the Canada lynx as a threatened species created a situation in which Forest Management plans had to be updated. The lands in these nominations that are co-incident with the E Seam project area contain lynx habitat, and therefore, were deferred from processing until supplemental NEPA review regarding lyiix could be completed. The FS Rocky Mountain Regional Office led this effort through preparation of a regional EIS. Due to lack of specificity in this analysis for oil and gas leasing, the GMUG undertook its own effort to update the 1993 oil and gas leasing analysis for lynx. This was completed in 2005. Prior to that time, gas lease nominations containing lynx habitat could not be processed. On-going litigation. regarding the 2001 RACR has also prevented placing these nominated lands on a gas lease sale (see Chapter 1, Roadless Area Conservation Rule). Currently, the national forests are deferring processing gas lease nominations in inventoried roadless areas pending guidance on how to notice leases with IRA ].ands. Consequently, the lands in these nominations that are co-incident with the E Seam project area contain IRA lands that cannot currently be forwarded for to BLM for gas leasing. The FS is actively exploring inechanislns consistent with Judge La.porte's reinstatement of RACR that would permit BLM ].easing of these gas parcels. Direction may include issuing oil & gas leases with a no surface occupancy stipulation. To summarize, the natural gas that may be vented from the methane drainage wells cannot be captured until gas leases are in place. Forwarding gas lease nominations to BLM for competitive sale that contain IRA lands is currently limited because of on-going issues related to the 2001 RACR. Gas Resource Information Gas quantity and quality information from operations in B Seam reserves (to the north and northeast of the project area) were used to understand the feasibility of capturing the gas resource, should it be possible from a leasing standpoint. MCC provided infornation related to gas-in-place evaluation done for the E Seam. BLM evaluated this data and provided technical information (project file) on what would be needed to capture the gas (if it were under lease) and take it to a pipeline, or use it in other ways. Their findings include that in order to send the gas from the methane vent wells to a pipeline for ultimate sale, a gas treatment facility would be necessary because the gas emitted from the mine does not meet basic pipeline quality. Primarily, the level of inert constituents in the gas (carbon dioxide, nitrogen, air, others) exceeds the pipeline standard limit of 3 percent for inert constituents. Based on gas emission data from. mining the B Seam at the West Elk mine, inert constituents range from 6 percent to 77 percent. For the purposes of this analysis it is assumed that gas emissions from the E Seam would have a similar range of inert constituents. There would also be a need for a gas compression facility. Typically pipelines need Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS 45