2008-06-09_PERMIT FILE - C1980007 ‎(6)‎

• Permit No: C1980007
• IBM Index Class Name: Permit File
• Doc Date: 6/9/2008
• Doc Name: Exhibit 79 Part 2
• Section_Exhibit Name: Exhibit 80 Drilling Activities - TR111
• Media Type: D
• Archive: No

Response to Comments

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Table 5-1
DEIS Comments and Responses
Commenter Comment Comment/Response

alternative (FEIS, Chapter 2, No Action Alternative and Chapter 3,
Inventoried Roadless Area). It is the Decisionmaker's role to weigh
consequences and make approvals consistent with the purpose and need, legal
framework, and decision space.
According to FS knowledge of the history and current conditions of this
portion of the West Elk IRA, the area retains little roadless character (see the
existing condition discussion, and effects on roadless character in the EIS,
Chapter 3.)
Colorado Wild, et 19 Before the project proceeds, the Forest Service must fully consider one or
al. more alternatives that would not construct roads and/or well pads in the IRA.
Any alternatives so developed should be issued in a supplement to the DEIS
and circulated for public comment.
RESPONSE: Effects to IRAs was identified as an issue to be addressed in the
EIS (Chapter 1, Issues). Effects are disclosed in the DEIS and FEIS. See
responses to Colorado Wild et al. comments 2, 15, 16, 17 and 18.
Colorado Wild, et 20 One or more alternatives that would construct and maintain the methane
al. drainage facilities without the construction of roads in the roadless area.
RESPONSE: See responses to Colorado Wild et al. comments 15, 16, 17, 18
and 19.
Colorado Wild, et 21 One or more alternatives that would construct and maintain the methane
al. drainage facilities from outside the roadless area (including alternatives that
contemplate postponing mining operations under roadless areas until drilling,
venting, and other related technologies improve).
REPPONSE: Methane drainage facilities are mapped approximate to where
they are anticipated to be needed based on approved mine plans and coal
resource recovery plans. Wherever possible, methane drainage wells are
drilled on an angle (i.e. directionally), however the over-burden is rather
shallow and there is not enough vertical distance to drill diagonally and place
all MDWs outside of roadless (see EIS, Chapter 2, Proposed Action). With
approved leases and mine plans, it is not within the discretion of the FS to
postpone mining activities. The FEIS has been revised to include additional
language about the status of other current technologies (see FEIS, Chapter 2,
Alternatives Considered but Eliminated from Detailed Study). And an
alternative considered in detail added considering not operating in roadless.
Colorado Wild, et 22 One or more alternatives, other than simple venting to the atmosphere, that
al. would capture and remove methane from the mine workings.
RESPONSE: The DEIS and FEIS address this concept in Chapter 2,
Alternatives Considered but Eliminated from Detailed Study. There are
several components involved with capturing and moving the gas.
First, it is important to understand that the federal coal reserves and the
federal gas reserves are separate mineral estates, and are leased separately. A
Supreme Court case (Southern Ute Indian Tribe v. Amoco Production
Company) affirmed that the separated nature of these estates.
In this ro'ect area, the federal as resource is not under lease. Without a
Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS 179