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project would release 7,000,000 cubic feet of methane daily, and contribute the equivalent of <br />960,960 to 1,131,200 metric tons of C02 into the atmosphere annually. Id. Th is one project <br />would therefore increase the greenhouse gas emissions resulting from fossil fuel combustion in <br />Colorado each year by a full 1.3%. Id.3 <br />Despite the staggering amounts of CO2 equivalent that would be released as a result of <br />this project, the Forest Service concluded that the impact from the additional methane released <br />by this Project "would not be considered a significant effect on the human environment." Project <br />FEIS at 61. This decision is clearly erroneous. As the U.S. Environmental Protection Agency <br />("EPA") noted in its comments to the Project DEIS, even before this project, the "West Elk Mine <br />was the fourth largest emitter of methane from an underground coal mine in the US and is one of <br />only 12 mines in the US that employs a degasification system but does not capture the drainage <br />methane." See letter of L. Svoboda, EPA to C. Richmond, USFS (Aug. 7, 2007) at 5 ("EPA <br />Comments on Project"), attached with additional materials at Exh. 4. The EPA stated: "We <br />think that this indicates that this mine's methane emissions are substantial relative to other <br />underground US coal mines." Id. As a result of these significant methane emissions, the EPA <br />urged the Forest Service to "include [in the FEIS] a qualitative discussion of the effect of <br />methane emissions and climate change." Id. at 7. <br />Despite EPA's request that the Forest Service conduct "a qualitative discussion," and the <br />agency's own determination of the effort required to mitigate the impacts of methane venting, <br />the Forest Service concluded in two sentences in its ROD that global climate change is a non- <br />' Further, the Forest Service states that offsetting the carbon dioxide equivalent of West <br />Elk's methane venting through one method of carbon sequestration - tree planting - would <br />require planting 1.7 million trees or 6,000 acres of previously unforested lands. Project FEIS at <br />61. Surely an action whose mitigation would require such a massive undertaking is <br />"significant." <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 7