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Introduction and Previous Studies and Findings from Work Conducted at West <br />Elk Mine <br />Introduction <br />Raven Ridge was contracted by Earthjustice to perform an independent evaluation of publicly available <br />methane emissions data submitted for the West Elk Mine, by Mountain Coal Company. Data reported to <br />EPA and available to the public includes volumes and concentrations of methane liberated from the <br />West Elk Mine for the years 2011 through 2016. This data was used to generate forecasts of methane <br />emissions that could be liberated from the proposed lease expansion areas if Mountain Coal Company is <br />allowed to mine the coal contained within the lease areas. These forecasts comprise gas that could be <br />emitted from the drainage and ventilation systems. Raven Ridge used this data to develop a conceptual <br />design for abating the emissions. <br />Prior EPA Work <br />Beginning in December 2003, Raven Ridge Resources, Incorporated (Raven Ridge), as a contractor to the <br />United States Environmental Protection Agency's (USEPA) Coalbed Methane Outreach Program (CMOP), <br />organized meetings with West Elk Mine management and various stakeholders, including project <br />developers, electricity providers, US Forest Service (USFS) and US Bureau of Land Management (USBLM), <br />to discuss the feasibility of siting a power generation facility at the mine, utilizing excess CMM drained <br />from the mine workings. At the time, the mine was using a portion of the drained CMM to heat the <br />intake air, while the remaining majority of the drained gas was vented to the atmosphere. Over the <br />course of these meetings, discussions evolved around the amount of gas available for use, types of <br />equipment best suited for the mine's application, ownership of the power distribution system, wheeling <br />the power to market, the potential to generate greenhouse gas emission reduction credits, and other <br />obstacles and challenges of power generation in the North Fork Valley. At the same time, West Elk Mine <br />management evaluated proposals to generate liquefied natural gas (LNG) using the excess drained <br />CMM, and to develop the ventilation air methane (VAM) resources. <br />Discussions continued at the beginning of April 2004, regarding power generation at the mine and its <br />distribution through Tri-State Generation & Transmission, via the local cooperative power distributor, <br />Delta -Montrose Electric Association (DMEA). A representative of Aspen Ski Company also participated in <br />the discussions, as did representatives of Holy Cross Energy, the electricity provider to the Aspen region. <br />However, West Elk Mine management decided not to move forward with developing a power project at <br />that time. <br />In 2007, Raven Ridge, representing an industry client, resumed discussions with MCC, a subsidiary of <br />Arch Coal and owner of the West Elk Mine, in their offices in Grand Junction, and with Arch's corporate <br />management in St. Louis. Arch again expressed interest in pursuing a methane recovery and use project <br />at the mine, but ultimately decided against project implementation. <br />Techno-Economic Study Commissioned by MCC <br />Arista Midstream Services was commissioned by MCC in 2009 to evaluate an earlier study to determine <br />the viability of operating a methane recovery and use project at the West Elk lease site, utilizing the <br />2 <br />