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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />32 <br />generating power or flare it in ways that lowers its climate impact. 95 First, methane can be <br />removed by moving vast quantities of air, including dilute quantities of methane, through a <br />mine’s ventilation system. This is termed “ventilation air methane” (often called “VAM”). <br />Second, methane drainage wells drilled into the coal seam from above can be used to capture, <br />flare, or (more commonly) vent methane directly into the atmosphere. A number of underground <br />coal mines operating on federal lands use both methods to remove methane. This includes the <br />West Elk Mine, which has thus far resisted all voluntary incentives to either capture or flare its <br />methane emissions and instead currently emits all of its methane directly into the atmosphere. <br /> <br />Studies show that flaring results in an 87% reduction in greenhouse gas emissions <br />compared with venting methane directly into the atmosphere.96 As a State of Colorado 2016 <br />report found: <br /> <br />From a climate change standpoint, emitting carbon dioxide is much less harmful <br />on the environment than a mine’s direct emission of methane into the atmosphere. <br />Accordingly, flaring methane, which converts the residual gas emission to carbon <br />dioxide, has nearly the same environmental impacts as using methane to generate <br />electricity or heat.97 <br /> <br />Further, the report documents recent changes in state and federal regulation of power that <br />has improved the financing environment for coal mine methane mitigation and power projects. <br />The report notes that a 2015 FERC ruling may make it easier for coal mines, including West Elk, <br />to sell power produced from coal mine methane to utilities: <br /> <br />FERC’s decision could enable [coal mine methane] project developers to <br />overcome industry barriers by securing reasonable power supply contracts with <br />utilities in Tri-State’s service area in western Colorado, where most of the “high <br />value” [coal mine methane] emission targets are located.98 <br /> <br />Even before these recent changes, methane capture and flaring had been used by mines <br />throughout the country, and either could be or already have been used by mines within the <br />planning area. The Colorado report concludes that there is a potential to generate 17.4 megawatts <br />of electricity from ventilation air methane at West Elk, and concludes that it is technically <br /> <br />95 In comments on BLM’s ANPR for the coal mine methane rulemaking, Sierra Club, Center for <br />Biological Diversity, WildEarth Guardians, Earthjustice and others provided detailed <br />recommendations listing feasible and immediately available mine methane mitigation measures. <br />See Comments by Sierra Club, et al., 1004-AE23, Waste Mine Methane Capture, Use, Sale, or <br />Destruction, Advance Notice of Proposed Rulemaking (June 30, 2014) (attached as Exhibit 32). 96 Daniel J. Brunner & Karl Schultz, Effective Gob Well Flaring 724 (1999) (attached as Exhibit <br />33). 97 State of Colorado, Coal Mine Methane in Colorado, Market Research Report at 14 (Mar. <br />2016), available at: <br />https://www.colorado.gov/pacific/sites/default/files/atoms/files/Coal%20Mine%20Methane%20 <br />Report%202016%20FINAL%203_2016.pdf (attached as Exhibit 34). 98 Id. at 13-14.