2016-12-12_REVISION - C1996083 (2)

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4. A more involved public process is needed. The most notable feature of Bowie’s application is its lack information. Coal gasification systems like the one proposed here have rarely been constructed in the United States. In fact, it appears that only two similar facilities are in operation anywhere in the country: in Mississippi and Indiana. Additionally, no literature, scientific studies or even rudimentary information on the “experimental” “patent-pending” DAXIOM technology described in the application or on the parent company El Camino Duro Investments, Ltd. is available. This lack of data supporting the assertion that this system will operate in the way its described makes it impossible for the Division to assess Bowie’s proposal. On top of that, the BLM and the Division have little if any experience permitting such a project and have no established processes or procedures for assessing the viability or the impacts of the proposal. A glaring lack of information along with a deficient process for evaluating the project leads to the undeniable conclusion that additional time and information is needed to adequately review Bowie’s request. If federal and state agencies are unable to understand and evaluate Bowie’s proposal, it is likely that the public – which will be most impacted by the project – will not be able to provide meaningful input. The state should extend the deadline for comment and hold a public hearing to engage the local community. 5. Community Economic Considerations The economies of Delta County, and specifically the North Fork Valley, have experienced a dramatic shift in recent years. Numerous factors, including declining demand for coal domestically, a larger market- based shift away from coal to natural gas and renewable energy, and the fire at the Elk Creek mine, have resulted in the closure of multiple local mines. The closures have led to a loss of high-paying jobs and significant budgetary shortfalls at the local government level. The North Fork Valley community, and Delta County more broadly, have both worked proactively toward a more diverse and sustainable economy, which is necessary to maintain the community’s quality of life. This means becoming less dependent on volatile extractive industries. Despite these proactive efforts, the potential of a revitalized coal industry has appeal and Bowie’s proposal has caught the attention of many local decision makers who have touted the potential economic benefits. However, this proposal is not likely to deliver the jobs and economic benefits many believe it might. As Bowie notes in its application, “The DAXIOM itself requires few employees to operate the plant…” and “The Plant operates at atmospheric pressure, eliminating the need for personnel specially trained…”. Additionally, as proposed, the system will be used to process existing mine waste and will not result in additional mining. Realistically, few jobs will be created, those jobs would not require specialized training, and therefore any new jobs will likely be much lower-paying than an average mining job. This information must be presented to the public so it can adequately and rationally assess the advantages and disadvantages of permitting such an operation. Lastly, if Bowie and the local community are truly interested in repurposing the mine, creating jobs and turning a profit, better solutions exist. The capture and sale of coal mine methane and/or electricity generated from the use of coal mine methane has proven to be both profitable and beneficial for the environment. We believe that the public would be better served if Bowie assessed the viability of a proven technology rather than risk the community’s natural resources. 6. Conclusion