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1980-007. This permit was most recently renewed in 2011 and West Elk submitted renewal <br />applications in 2016. Further, because much of the coal mined by West Elk is leased federal <br />coal, mining has also required approval from the Secretary of the U.S. Department of the Interior <br />in the form of a "mining plan" issued pursuant to 30 C.F.R. § 746. Over the years of West Elk's <br />operation, the Secretary's Office has approved a number of mining plans and modifications of <br />those plans. Most recently, the Secretary approved mining plan modifications authorizing coal <br />extraction from federal coal leases COC -67232 (approved June 10, 2008), C-1362 and COC - <br />56447 (approved July 31, 2008), and C-1362 and COC -67232 (approved January 15, 2009). <br />While the West Elk mine is an underground mine, the operations require extensive <br />surface disturbance associated with methane venting. While normally methane gas, which is a <br />safety hazard, is vented through a mine's central ventilation system, West Elk must vent methane <br />through drainage wells drilled above the mine. The U.S. Forest Service has explained: <br />In recent years, the coal mines operating in the Somerset coal field have experienced the <br />build-up of methane gas in the underground workings after the overlying rock strata have <br />subsided into the mine void (called the gob).... <br />Typically, the in -mine ventilation system cannot effectively keep methane levels within <br />safe working range, therefore additional methane liberation methods have to be <br />employed. Existing operations at the West Elk Mine, as well as other mines in the North <br />Fork Valley, have used a system of methane drainage wells (MDWs) to assist in <br />liberating methane from underground mine workings. These MDWs are drilled from the <br />land surface into the strata overlying the coal, and use an exhausting blower to pull gas <br />from the rock formation, and subsequently air from the mine .... Due to the large amount <br />of methane found in the West Elk Mine, the agency requires MDWs to be placed every <br />1,000 to 750 ft. along the longwall panel.... Methane drainage well construction is <br />essential for operating longwall operations in the North Fork Valley. <br />U.S. Forest Service, Final Environmental Impact Statement, Federal Coal Lease Modifications <br />COC -1362 and COC -67232 (August 2012) at 51 (hereafter referred to as the "FEIS"), available <br />online at <br />http•//al23 g akamai net/7/123/11558/abcl23/forestservic.download.akamai.com/11558/www/ne <br />pa/68608 FSPLT2 263949.pdf. <br />According to West Elk's most recent reports to the U.S. Environmental Protection <br />Agency ("EPA"), the mine emitted 16,115 tons of methane in 2016, making it the single largest <br />industrial source of methane emissions in the State of Colorado. See EPA, "West Elk Mine <br />Greenhouse Gas Emissions," available at <br />hgps:Hahadata epa gov/ahjzp/service/facilityDetail/2016?id=1010310&ds=E&et=&popup=true. <br />Methane is not only a safety hazard, it is a potent greenhouse gas. The Intergovernmental <br />Panel on Climate Change ("IPCC") reports that methane is 34 times more potent than carbon <br />dioxide over a 100 -year period and 86 times more potent over a 20 -year period See IPCC, <br />Climate Change 2013: the Science Basis. Working Group I Contribution to the Fifth <br />Assessment Report of the Intergovernmental Panel on Climate Change. Cambridge University <br />