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Agency for Int'1 Development, "U.S. Government Accomplishments in Support of the Methane <br />to Markets Partnership" (Sep. 2007), excerpt attached as Exh. 32.19 <br />Further, the Project FEIS dismissed the option of capture in part on the grounds that the <br />distance between the gas wells and a pipeline - "over 10 miles" - suggested that "the quantity of <br />gas potentially available may not warrant the investment in a pipeline." Project FEIS at 46. <br />However, the Forest Service provides no data, estimates, or models to test this theory. <br />Additional study might well show such an approach to be economical, given that numerous <br />mining operations capture gas for transport to pipelines. See EEI Geophysical Report at 3, 5. <br />The Forest Service also rejected the option of "using coal mine vent gas for electrical <br />generation" since BLM could not find data on gas volume and equipment requirements on those <br />websites showing that electrical generation was possible. Project FEIS at 46. In other words, <br />because the Forest Service could not discover the information it needed via a few web searches, <br />it concluded there was not sufficient data to consider using captured methane on-site to generate <br />electricity. This is an arbitrarily low bar to set for dismissing an alternative, particularly given <br />the ample evidence that a major American corporation - Caterpillar - is building scores of <br />engines that turn coal mine methane at working mines into power around the world, including in <br />China. 20 General Electric is also building engines used to generate power from working mines in <br />19 The Forest Service apparently does not argue that technological or safety barriers <br />prevent capture and use of methane. It could not do so, given the experience at the Aberdeen <br />Mine in Utah, the Jim Walter Mine in Alabama, and numerous mines around the world. See also <br />EEI Geophysical Report at 1 ("the collection of methane has for over 20 years been routinely <br />undertaken at US and international coal mines with no adverse affects to coal operations"). <br />20 See "Caterpillar Powered Coal Methane Gas Project In China Will Be Largest In The <br />World" (Sep. 2006), available at <br />http://www.cat.com/cda/components/fullArticle?m=37523&x=7&id=606907 (last viewed Apr. <br />27, 2008) (Caterpillar will supply "60 methane-gas-powered generator sets to produce 120 <br />megawatts of power at the Sihe Coal Mine in Jincheng City, Shanxi Province, China," and <br />stating that "The power plant project is expected to improve methane gas ventilation at the mine <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 29