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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />34 <br />economic feasibility of methane capture and flaring projects at the West Elk mine in <br />Colorado.106 <br /> <br />In 2009 BLM directed Mountain Coal Company, which owned and operated the West <br />Elk Mine near Somerset, Colorado, to analyze the economic feasibility of capturing and using <br />coal mine methane released into the atmosphere at West Elk. Mountain Coal Company, through <br />a series of consultants, carried out a study but concluded that there were no available <br />technologies that could capture methane in a way that was economically feasible. <br /> <br />Dr. Power’s report provides a critical review of the Mountain Coal Company’s economic <br />analysis of the coal mine methane releases from the West Elk drainage wells. He concludes that <br />there were in fact at least three economically viable means of capturing methane, two of which <br />had been considered and rejected by Mountain Coal Company. These methane mitigation <br />strategies include flaring, electricity generation, and conversion of methane into liquid natural <br />gas. Notably, these alternatives became economically feasible when the economic value of <br />reducing emissions of methane was incorporated into the analysis. The company’s conclusion <br />that there was no economically feasible solution to the methane waste problem was tied in part to <br />its flawed assumption that there was no economic value associated with the reduction of methane <br />emissions. <br /> <br />Moreover, rather than treating any pollution control technology as part of the cost of <br />doing business, Mountain Coal Company asserted the need to make greater than a 10% return on <br />investment in that technology in order to be considered economically feasible. While Dr. <br />Power’s analysis shows how the company could nonetheless meet that criterion, that should not <br />be the standard for BLM’s determination to consider an alternative that would require methane <br />capture or flaring as requisite for obtaining authorization to lease federal coal within the <br />Uncompahgre planning area. <br /> <br />Finally, Dr. Power’s case study refutes seven critical and erroneous assumptions that <br />Mountain Coal Company made to support its rejection of economic feasibility, including the <br />volume of methane available for use, the cost of operating methane collection systems, the cost <br />of electricity generation (applicable where a mine uses recovered methane to generate <br />electricity), the length of time methane recovery equipment can be used, and treating pollution <br />control costs as a corporate commercial investment, among others. <br /> <br />Given the new science documenting the urgency of reducing methane emissions to <br />combat climate change and the failure of voluntary incentive programs to encourage methane <br />mitigation, here BLM must consider an alternative that requires companies to utilize <br />technologies that capture and/or flare coal mine methane pollution as a condition for <br />authorization to mine federally-owned coal in the Uncompahgre planning area. <br /> <br />106 Thomas Power, An Economic Analysis of the Capture and Use of Coal Mine Methane at the <br />West Elk Mine, Somerset, Colorado (Dec. 2011) (attached as Exhibit 38).