2008-06-20_REVISION - C1980007 - Laserfiche WebLink

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EARTHJUSTICE Because the earth needs a good lawyer BOZEMAN, MONTANA DENVER, COLORADO HONOLULU, HAWAII INTERNATIONAL JUNEAU, ALASKA NEW YORK, NEW YORK OAKLAND, CALIFORNIA SEATTL r, WASHINGTON TAI. I. AHASSFF FLORIDA WASHINGTON, D C File 1711 June 20, 2008 RECEIVED Colorado Mined Land Reclamation Board JUN 2 0 .2008 1313 Sherman Street, Room 215 Division of Reclamation, Denver, CO 80203 Mining and Safety Via Hand Delivery Request of Rocky Mountain Clean Air Action et al. for Formal Hearing on the Proposed Decision by the Colorado Division of Reclamation, Mining and Safety to Approve Technical Revision Application No. 111 (TR-111) for the West Elk Mine (Permit No. C-1980-0007) Dear Board Members: In accordance with Section 2.08.4(6)(b)(iii) of the Regulations of the Colorado Mined Land Reclamation Board for Coal Mining (revised September 14, 2005) ("the regulations"), we request a formal hearing before the Colorado Mined Land Reclamation Board ("the Board") to contest the proposed decision by the Colorado Division of Reclamation, Mining and Safety ("DRMS") to approve Technical Revision Application No. 111 (TR-111) for the West Elk Mine (Permit No. C-1980-0007). TIMELY SUBMISSION OF REQUEST Notice of this proposed decision was initially published in the Delta County Independent on June 11, 2008. Section 2.08.4(6)(b)(iii) of the regulations provide ten days for receipt by the Board of a request for a hearing. Consequently, this request is timely. STATEMENT OF FACTS DRMS has issued a proposed decision for Technical Revision 111 ("TR-111") for the West Elk Mine ("the Mine"). This Technical Revision would authorize the drilling of methane drainage wells for the Mine's operation of longwall panel E-1 (an expansion of the Mine's subsurface operations that was authorized in Permit Revision 10). TR-111 would authorize approximately 16 wells from 14 well pads, six access roads, and disturbance of ten acres. TR- I I I is the first element of a larger methane drainage project; subsequent elements of the overall project are being considered separately by DRMS under Technical Revision 112 ("TR-112") to the Mine permit. Altogether, the Mine proposes to construct 15.8 miles of new road and to drill 168 wells to permit methane venting. According to U.S. Forest Service analysis, seven million cubic feet of methane may be vented each day from the Mine expansion. The methane emissions permitted by the Board will be one of the largest single contributors to global warming in the State. According to the U.S. Forest Service's environmental impact statement, the methane emitted will have the heat-trapping equivalent of approximately one million metric tons of C02 released into the atmosphere annually, about 1.3% of the total in Colorado from all fossil fuel 1400 GLENARM PLACE, #300 DENVER, CO 80202-5050 T: 303.623.9466 F: 303.623.8083 E: eajusco@earthiustice.org W: www.earthiustice.org