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2008-06-20_REVISION - C1980007
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2008-06-20_REVISION - C1980007
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Last modified
8/24/2016 3:33:23 PM
Creation date
6/23/2008 9:47:20 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
REVISION
Doc Date
6/20/2008
Doc Name
Request of Rocky Mountain Clean Air Action for Formal Hearing on the Proposed Decision
From
EarthJustice
To
DRMS
Type & Sequence
TR111
Email Name
TAK
Media Type
D
Archive
No
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Already, decreases in snowpack, less snowfall, earlier snow melt, more winter <br />rain events, increased peak winter flows, and reduced summer flows have been <br />documented. Scientists have recently attributed more than half of these changes <br />in the West between 1950 and 1999 to the effects of heat-trapping pollutants. <br />As global warming continues, the IPCC also predicts more intense and longer <br />droughts .... <br />See "Hotter and Drier: The West's Changed Climate" at v (March 2008), excerpts attached as <br />Exh. 2.' <br />Responding to these findings, Colorado Governor Bill Ritter, Jr., recently issued a <br />groundbreaking Executive Orders calling for, among other things, a 20% reduction in <br />greenhouse gases below 2005 levels by 2020 and an 80% reduction below 2005 levels by 2050. <br />According to Governor Ritter, "Many sectors of Colorado's economy, including agriculture, <br />recreation, skiing, and tourism, could experience significant changes and impacts if emissions <br />are not reduced." Executive Order D 004 08, "Reducing Greenhouse Gas Emissions in <br />Colorado" (April 22, 008) at 1, attached as Exh. 3. <br />Despite the fact that the Governor of Colorado has called for greenhouse gas reductions <br />in order to safeguard the state from significant environmental and economic impacts, and that <br />"[c]oal mine emissions account for approximately ten percent of worldwide methane emissions," <br />a number that is expected to rise', the Project's Final EIS nevertheless failed to analyze properly <br />the cumulative effects that the Project's released methane would have on global warming. The <br />EIS acknowledged that "[m]ethane is over 20 times more effective in trapping heat in the <br />atmosphere than CO2 over a 100-year period." Project FEIS at 60. It also calculated that the <br />' The full report is available at <br />http://www.rockymountainclimate.org/website%20piclures/Hotter%20andYo2ODrier.pdf (last <br />viewed Apr. 27, 2008). <br />z L. Lyman, "Coalbed Methane: Crafting a Right to Sell Form an Obligation to Vent," 78 <br />U. of Colorado L. Rev. 613, 615 (2007). <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 6
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