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OCR <br />MOUNTAIN <br />CLEAN AIR ACTION <br />Clean Air For Healthy Children and Healthy Communities <br />RECEIVED <br />February 13, 2008 FEB 13 2000 <br />Mr. Ron Cattany, Executive Director Division of Reclamation, <br />Colorado Division of Reclamation Mining and Safety Mining and Safety <br />1313 Sherman St., Rm. 215 <br />Denver, CO 80203 <br />FAX: 303-832-8106 <br />Re: Issues DRMS Must Consider in Reviewing Permit and Technical Revisions <br />for Expansion of the West Elk Mine (PR12, TR111 & TR112). <br />Dear Mr. Cattany: <br />We understand that the Division of Reclamation Mining and Safety (DRMS) may soon <br />issue a Permit Revision to facilitate below-ground expansion of Mountain Coal Company's <br />underground West Elk Mine northeast of Paonia.l In order for the coal to be safely mined in the <br />expansion area, huge amounts of methane must be vented from the coal seam. The Mine <br />proposes to construct 15.8 miles of new road and to drill 168 wells to permit this venting. <br />DRMS is considering the activities related to methane venting, including the surface impacts of <br />well drilling and road construction, separately from the underground operations under two <br />Technical Revisions.2 <br />For the reasons -set forth below, we urge DRMS to require that Mountain Coal Company <br />address at the same time the above- and below-ground impacts of the coal mine expansion in a <br />single Permit Revision. <br />Further, we urge DRMS to include in any permit or revision measures that will require <br />the Mine to capture or flare methane. Methane is one of the most potent greenhouse gases. <br />Failure to include provisions to capture or flare methane may undermine DRMS's duty to <br />"minimize disturbances and adverse impacts of the operation on fish, wildlife, and related <br />environmental values." In addition, methane is a commodity that, if vented to the atmosphere, <br />will be wasted, depriving the residents of Colorado of a valued resource and significant revenue, <br />while missing an excellent opportunity to reduce impacts to other state resources. <br />' Mountain Coal Company has filed what the DRMS has characterized as a "complete <br />application" for a Permit Revision (PR 12) to the Mountain Coal Company's Mining and <br />Reclamation Permit No. C-80-007. <br />Mountain Coal Company seeks approval to construct the drainage wells under two <br />Technical Revision (TR111 and TR112) to the existing permit. <br />Rocky Mountain Clean Air Action • www.ourcleanair.orq <br />1536 Wynkoop, Suite 302 • Denver, CO 80202 • (303) 454-3370 • rmcleanair@gmail.com