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22, 2008), and attached as Exh. 14; see also EEI Geophysical Report at 4 ("Off the shelf systems <br />are available from companies that provide flaring systems that are designed for and are in use <br />around the world over coal mines."). This is exactly the type of evidence that the Forest Service <br />should have considered in its "Supplemental Information Report," rather than simply taking the <br />word of a single MSHA staffer. <br />b. MSHA Approved a Processes that Is Virtually Identical to Flaring <br />at the West Elk Mine. <br />Second, it is odd that MSHA states that flaring could not be approved by the agency <br />when MSHA has already permitted the West Elk Mine to burn methane to heat its mine in the <br />winter, a process that is the functional equivalent of flaring. See U.S. EPA, Coalbed Methane <br />Extra (Feb. 2004) at 5, attached as Exh. 15. EPA has described West Elk's mine heating project, <br />begun in the fall of 2003, as follows: <br />West Elk Mine in Western Colorado ... is now using gob gas recovered from <br />sealed areas through in-mine horizontal wells to heat mine ventilation air. The <br />gas is collected underground and pumped to the surface with centrifugal blowers. <br />The gas is then transferred approximately 1/2 mile to the heater facility by <br />pipeline and distributed to four combustors using a 50 hp positive displacement <br />blower for each combustor. Designed by Northwest Fuel Development ... the <br />combustors consume approximately 900 cfm (1,037 mcfd of methane) of the <br />5,100 cfm collected from the in-mine boreholes. The concentration of the gob <br />gas is currently approximately 80% methane.... Mountain Coal ... initiated the <br />project with the goal of reducing a portion of their methane emissions to the <br />atmosphere. <br />Id. In other words, West Elk is recovering methane from the gob through the mine's methane <br />drainage system and burning it, the same process as flaring. MSHA approved schematics <br />supplied by the mine showing the types of safety devices (e.g., flame arresters) used to ensure <br />that burning methane venting from the mine could take place without endangering miners <br />underground. See letter of A. Davis, MSHA to A. Olsen, Mountain Coal Co., re: West Elk Mine <br />Ventilation Plan (Dec. 1, 2006) at 32-41, excerpts attached as Exh. 16;i d. at 38 (schematic <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 16