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produces no. benefit to the government other than coal revenue, it is apparent that any positive <br />result from capturing of the methane, including reducing greenhouse gas impacts or improving <br />safety, is beneficial. The Forest Service acknowledges, on the eighth page of their responses to <br />EPA comments, that MCC is currently using some of ventilated methane to run heaters in the <br />Sylvester Gulch shaft. See Exh. 4 at fax page 17 of 32. Apparently such a use, that allows the <br />operator to continue operations in sub-freezing weather, provides a benefit to the government or <br />it would otherwise be illegal. The only apparent benefit to the government comes from increased <br />coal revenues from continued mine operation. The same consideration should be given to <br />capturing methane, which would allow the mine to continue operations while mitigating its <br />global warming impacts. <br />b. Economic Concerns Do Not Render Capture an Infeasible <br />Alternative. <br />While methane capture may cost money, there can be no doubt that capture can be <br />economically performed, since it is ongoing at numerous mines in the U.S. and around the world. <br />As noted above, methane vented at the Aberdeen mine was captured methane for sale and use. <br />Outside investors subsidized that methane capture to reap carbon credits, a factor the Forest <br />Service ignores in its analysis. See A. Best, Mining New Carbon Offset Market, Pique <br />Newsmagazine (Mar. 26, 2008), attached as Exh. 27 and available at <br />www.piquenewsmagazine.com/pique/index.php?content=Coal+bed+methane+1513 (last viewed <br />Apr. 23, 2008). Jim Walter Resources has been capturing coal mine methane from its Alabama <br />mines since 1979 through its Black Warrior Methane subsidiary. These facilities capture <br />methane from gob wells. Jim Walter Resources, Inc., webpage, <br />wwwjimwalterresources.com/Subs.html, attached as Exh. 28 (last viewed Apr. 23, 2008). In <br />fact, today a Canadian energy company, Biothermica, announced that it had obtained MSFIA <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 27