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Appeal Deciding Officer 16 benefits of destroying or capturing ventilation air methane from the mine and the overriding need to protect the safety of underground miners. The USFS "no surface occupancy" stipulation for the lease modification places the suggested alternative methods to capturing methane outside the jurisdiction of the agency. Possible mitigation measures may be implemented by OMLLC on their existing leases, private land, or new BLM lease, but not on this lease modification due to the No Surface Occupancy stipulations. Furthermore, due to the size of the lease modification (and associated recoverable coal reserves) relative to the existing parent lease, and considering the degree to which the lease modification would extend the life of the entire mining operation, the proposed action will not cause significant additional impacts beyond what is permitted under the parent lease; therefore, the effects of the proposed action, as well as the alternatives discussed, essentially do not differ from the no action alternative. The environmental analysis adequately addresses whether VAM oxidation is a reasonable alternative to the proposed action. The record supports the deciding officer's decision. Therefore, I recommend that the Forest Supervisor's decision be affirmed on this point. Appeal Issue II -B . THE EA FAILS TO SUFFICIENTLY ANALYZE METHANE FLARING AS A REASONABLE ALTERNATIVE. The Elk Creek Mine removes methane not only through ventilation systems (as VAM), it also vents methane through drainage wells. Coal mine methane from drainage wells can be combusted, or flared, before it enters the atmosphere. Flaring results in 7.5 times fewer GHG emissions than venting methane directly into the atmosphere. Despite the potential benefits of methane flaring, the Forest Service dismissed detailed consideration of a flaring alternative without a rational basis. Methane flaring, however, is a reasonable, practical, effective, and feasible alternative to reduce the Lease Modification's GHG emissions. The EA should have analyzed a flaring alternative in detail because such an alternative would allow Oxbow to produce the coal within and adjacent to the Lease Modification, thereby fulfilling the project's purpose and need, while reducing the damaging impacts of methane pollution. The EA's stated explanations for failing to do so are arbitrary and capricious. The EA states the flaring cannot be implemented in the Lease Modification area because of the no surface occupancy stipulation. EA at 33, 47. While it is true that the NSO stipulation would prevent methane drainage wells — and thus flaring — within that area, nothing prevents the Forest Service from stipulating that any methane drained as a result of the Lease Modification should be flared. Given that, according to BLM, a half - million tons of coal could be mined outside of the Lease Modification as a result of the Forest Service's consent, it is likely that methane drainage will be required to safely mine that coal.31 The EA fails to address or depict the location of any methane drainage wells in the vicinity of the Lease Modification. Further, the Forest Service has authority to compel lease- holders to protect National Forest resources with lease stipulations, even if the harm will occur off the lease. See supra at 14.