2013-07-01_PERMIT FILE - X201322801 (3)

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BLM Uncompahgre Field Office Sunset Trail Area Coal Exploration Plan EA . it is inconsistent with the basic policy objectives for the management of the area (such as, not in conformance with the Resource Management Plan (RMP)); . its implementation is remote or speculative; . it is substantially similar in design to an alternative that is analyzed; or . it would result in substantially similar impacts to an alternative that is analyzed. Alternatives specific to this EA that were considered, but that will not be analyzed in detail, are discussed below. 2.4.1 Use Helicopters to Transport Drill Rig An alternative analyzing drilling using a drill rig that can be placed on site by a helicopter drill rig to avoid construction of access roads was considered; however, this alternative was not carried forward for detailed analysis because it is ineffective and technically infeasible. The geology of the exploration area is such that the aggregate material is not structurally sound; therefore, the drill hole must be cased. In order for the holes to be properly cased, the initial diameter must be wide enough to allow for casing and core extraction. This is not feasible to do with a drill rig that can be transported by helicopter because they are too small and not powerful enough. Furthermore, this alternative would not fulfill the purpose and need for the proposed action because it would not allow the exploration to be accomplished if the holes collapse before the core sample can be obtained. 2.4.2 Analyzing Only the Holes Proposed to be Drilled During 2013 An alternative was suggested by Wild Earth Guardians that would include only the four holes that MCC proposes to drill during 2013. This alternative was not carried forward for detailed analysis because it is ineffective as it would not provide the necessary information on the coal. This alternative would not meet the purpose and need of the proposed action because it would not effectively explore the coal leases consistent with the lease rights granted. 2.5 Scoping and Identified Issues The issues related to exploration are similar to those raised during scoping completed for the FEIS and its preceding EA. Issues raised were addressed in the FEIS and site specific impacts are disclosed in this EA. Additionally, the BLM, USFS, and OSM internally scoped the proposed action and identified issues as shown in Table 3. Wild Earth Guardians submitted comments as part of the appeal withdrawal from the Interior Board of Land Appeals and in comments submitted in April 2013. This project was added to the Uncompahgre Field Office's online NEPA register on April 29, 2013. 2.6 Plan Conformance Review 2.6.1 Forest Plan and Forest Service Regulations The amended Land and Resource Management Plan (Forest Plan) dated September 1991 (USFS, 1991), for the GMUG National Forests made provisions for exploration subject to the application of the coal unsuitability criteria established in 43 CFR 3461. The Forest Plan was reviewed in relation to the proposed action (FEIS, Section 1.7) (USFS, 2012a). The proposed action is consistent with the Forest Plan. June 2013 10