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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />33 <br />feasible to produce 20% of that amount or 3.49 megawatts of power.99 Additional climate <br />savings could be secured by putting to use the massive quantities of methane vented from West <br />Elk every day. In 2010 the mine vented nearly 3.5 million cubic feet of methane into the <br />atmosphere a day; in 2013, that number was about 2 million cubic feet per day.100 <br /> <br />Likewise, flaring is a viable alternative, both nationally and in the planning area. EPA <br />reported in 2014 that it had identified “40 projects where flaring has been practiced, either in <br />conjunction with energy recovery technologies or as a stand-alone mitigation technology,” and <br />that flaring projects had the advantage of being far less costly than coal mine methane energy <br />generation projects.101 <br /> <br />At the Elk Creek Mine, located just a few hundred yards west of the West Elk Mine— <br />Oxbow Mining has developed a system for capturing and utilizing coal mine methane to generate <br />electricity.102 Oxbow’s methane capture facilities include a flare that has been safely operated for <br />years.103 The Colorado Division of Mining, Reclamation and Safety (“DRMS”) approved this <br />project, including the flare, in March 2012.104 The State of Colorado reports that the Elk Creek <br />Mine has been safely and economically flaring coal mine methane at Elk Creek for over three <br />years as part of a system that generates electricity and revenue: <br /> <br />In 2012, Vessels Coal Gas, Inc. (Vessels) officially began generating GHG emission <br />reductions from the project under the Climate Action Reserve. Vessels had The Elk Creek Coal <br />Mine Methane Destruction and Utilization Project verified, registering the first offset credits via <br />the Climate Action Reserve in September of 2014 (CAR, 2015).105 <br /> <br />The Elk Creek mine project demonstrates that flaring of coal mine methane in the North <br />Fork Valley, as well as the use of such methane to generate electricity, is safe, technical feasible <br />and economically viable. <br /> <br />As with the Elk Creek example, methane capture and flaring mitigation measures could <br />similarly be implemented in ways that are economic at the West Elk Mine. In the 2011 case <br />study attached to this comment letter, Ph.D. economist Dr. Tom Power demonstrates the <br /> <br />99 Id. at Appendix D, page 38. 100 Id. at 31. 101 EPA, CMM Flaring: Technology and Case Studies (Sep. 2014) (attached as Exhibit 35). 102 See letter of J. Kiger, Oxbow, to B. Bowles, Colo. Div. of Mining, Reclamation & Safety, <br />at 1 (Oct. 14, 2011) (attached as Exhibit 36) (stating that “North Fork Energy LLC has <br />determined the economic viability of constructing and operating a facility to utilize mine <br />methane from Oxbow’s underground mine methane collection system” and seeking agency <br />approval for the same). 103 Id. at un-paginated attachment to letter. 104 See letter of J. Kiger, Oxbow to F. Kirby, Office of Surface Mining, (Mar. 15, 2012) <br />(attached as Exhibit 37). 105 State of Colorado, Coal Mine Methane in Colorado at 18 (attached as Exhibit 34).