2018-06-01_REVISION - C1980007 (2)

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methane venting operations within publicly accessible National Forest lands that are enjoyed for recreational and aesthetic reasons. Thus, Objectors are permitted to submit comments and objections on DRMS's proposal to approve PR -15. II. Basis for Objections, Request for Informal Conference and Site Visit Objectors object to DRMS's proposed approval of PR -15 and requests both an informal conference and site visit of the West Elk mine on the basis of this objection. Below are the issues that we anticipate raising at the informal conference: a. Unnecessary Roads and Reclamation The permit revision proposal calls for additional roads to be built for methane drainage wells ("MDWs"). We are concerned that the addition of unnecessary roads violates performance stands under Colorado regulations. MLRB Rule 4.18(5)(a) requires that roads be located and operated so as to avoid or minimize impacts to fish and wildlife species. Here, it is unclear why Arch has proposed additional roads for construction within the Sunset Roadless Area when it appears that the use of roads from adjacent private lands would provide sufficient travel to create new methane wells. See Permit Revision Map 3 (March 2018), attached as Exhibit 1. The construction of these new roads, without further explanation, do not seem to indicate that roads are being located and operated so as to avoid or minimize impacts to fish and wildlife species. Specifically, as the attached map (Exhibit 2) shows, Arch proposes to access all but one of the SST drill pads and all of the SST2 drill pads using new or existing roads on National Forest lands on the northeast portion of the map. See id. (noted by the roads marked with red "X's"). However, all of SST1 and SST2 drill pads could be reach with a lesser amount of new road construction on private land (see id., identifying "potential connector" roads with red loops), while permitting existing roads within the National Forest roadless area to be closed and reclaimed immediately. In short, building a few short roads on private land would eliminate the need for more damaging new road construction and continuing road use on National Forest land. DRMS must address whether the permit revision fails to ensure that roads are being located and operated appropriately, absolutely necessary. b. Concerns Over Unaddressed Air Quality Issues We are further concerned that the permit revision fails to provide evidence for how Arch Coal will protect fish, wildlife, and other related environmental values in relation to the mines methane and other air emissions, as well as "control and minimize air pollution" consistent with MLRB Rules and consistent with State and Federal air quality laws and regulations. Methane is a potent greenhouse gas, trapping more than 80 times the heat of carbon dioxide over the short term. The West Elk mine contains no provisions to limit methane pollution. Though a 2016 State of Colorado report stated that flaring can be a safe and Ll