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Request for Hearing on TR-I I 1 for the West Elk Mine (Permit No. C-1980-0007) Page 3 <br />June 20, 2008 <br />II. The Proposed Technical Revision Represents Analysis of Only One Element of a <br />Larger Project. <br />As described above, TR-l 11 is the first element of a larger methane drainage project <br />which is also being separately considered by DRMS under Technical Revision 112 (TR-1 12) to <br />the Mine permit. This is a distinction of separate projects on paper only; the methane drainage <br />project has been conceived of, and analyzed by the Forest Service as an, integrated whole. By <br />segregating the project into two Technical Revisions, DRMS has compromised the public's - <br />and its own - ability to comprehensively analyze and comment on the project. <br />III. The Methane Drainage Wells Will Be a Significant Source of Colorado Greenhouse <br />Gas Emissions. <br />The drainage wells to be authorized would release large quantities of methane from the <br />gob produced from the longwall operations. Methane is one of the most potent greenhouse gases <br />when released to the atmosphere uncombusted. <br />The "harms associated with climate change are serious and well recognized." <br />Massachusetts v. EPA, 127 S. Ct. 1438, 1455 (2007). According to Governor Bill Ritter: <br />Scientists tell us that to head off catastrophic disruptions to our environment and <br />society by the second half of this century-when our children and grandchildren <br />will be running this state-we must slash greenhouse gas emissions by 80 percent <br />below 2005 levels by 2050. <br />Governor Bill Ritter Jr., Colorado Climate Action Plan: A Strategy to Address Global Warming <br />(Nov. 2007) at 10, attached as Exh. 3. Thus, even a small increase in greenhouse gas emissions <br />in Colorado is significant because it makes it more difficult for the State to achieve the Action <br />Plan's ambitious goals. See also Executive Order D 004 08, "Reducing Greenhouse Gas <br />Emissions in Colorado" (April 22, 2008) at 1 (calling for, among other things, a 20% reduction <br />in greenhouse gases below 2005 levels by 2020 and an 80% reduction below 2005 levels by <br />2050, and stating that "Many sectors of Colorado's economy, including agriculture, recreation, <br />skiing, and tourism, could experience significant changes and impacts if emissions are not <br />reduced."), attached as Exh. 4. <br />In its environmental impact statement evaluating the surface impacts of the West Elk <br />Mine expansion and the overall methane drainage project, the U.S Forest Service wrote that <br />"[m]ethane is over 20 times more effective in trapping heat in the atmosphere than CO2 over a <br />100-year period." Exh. 1 (West Elk Final EIS) at 60. It also calculated that the methane <br />drainage project would release 7,000,000 cubic feet of methane daily, and contribute the <br />equivalent of 960,960 to 1,131,200 metric tons of CO2 into the atmosphere annually. Id. <br />Global warming presents a threat to fish, wildlife, and other environmental and social <br />values, and, consequently, to the interests of those seeking a hearing. See IPCC's Contribution