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mine in Australia;9 and in at least five UK Coal collieries.10 Research could locate no evidence <br />of any accidents in working mines resulting from the use of flares. See J. Hempel, EEI <br />Geophysical, "Preliminary Assessment of the Feasibility of Capturing and Using Coal Bed <br />Methane from the "E" Seam in the West Elk Coal Mine," Apr. 25, 2008 ('`EEI Geophysical <br />Report") (Exh. 6) at 4. In the United States, the State of Alabama's Oil and Gas Board has <br />adopted a regulation that permits flaring of coalbed methane gas. See Alabama Oil and Gas <br />Board Regulation 400-3-5-.03 ("Venting or flaring of gas from permitted coalbed methane gas <br />wells shall be allowed where necessary ...."); EEI Geophysical Report at 4. <br />The fact that flaring is used safely at numerous mines around the world disproves <br />Mr. Davis's assertion - relied upon by the Forest Service - that flaring at working mines is <br />somehow "unproven and has unknown/unanalyzed safety hazards." Indeed, at a conference <br />sponsored by EPA in St. Louis in September 2007, evidence was presented that methane flaring <br />at working coal mines was "state of the art," and that flaring to dispose of vented methane at coal <br />mines was "[s]imple, low cost and reliable to operate" with "[I]ow maintenance requirements." <br />See Harworth Power Ltd., CMM Flaring PowerPoint (Sep. 2007) at 6, 26, available at <br />htlp://www.epa.gov/cmop/dots/cmm_conference_sep07/uk-c oal_flaring.pdf (last viewed April <br />9 See U.S. EPA, Coal Methane Outreach Project, 2006 International News (last updated <br />Mar. 28, 2008), available at http://www.epa.gov/cmop/newsroomlinternational_2006.himl (last <br />viewed April 22, 2008) excerpts attached as Exh. 12, (stating that "XSTRATA Coal's United <br />Colliery has shown how to safely flair goaf (gob) gas at an active longwall mine and will <br />capitalize on the resulting greenhouse gas (GHG) abatement credits" and describing how the <br />mine was able to address safety issues.) <br />10 See United Kingdom's Coal Authority, Coal Mine Methane Activity Within The UK, <br />Coal Mine Methane Operators Activities, available at <br />www.coal.gov.uk/resources/cleanercoaltechnologies/coalminemethaneukactivity.cfm (last <br />viewed April 22, 2008), attached as Exh. 13, reporting that "UK Coal has a mixture of flares, <br />generators and gas utilisation for boilers at the majority of its operating collieries" and describing <br />flares at the following mines: Maltby Colliery (has "2 flares"); Kellingley Colliery (has "a <br />flare"); Rossington Colliery ("Has a flare"); Thoresby Colliery (has "a flare"); and Welbeck <br />Colliery (has "a flare"). <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 15