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municipalities of the Front Range of Colorado where 85% of the state lives." Udall testimony <br />at 3.6 <br />Given these impacts, and the fact that no other State agency regulates methane venting, <br />DRMS has cause to require MCC "[t]o the extent possible" to minimize the impacts of global <br />warming by requiring the use "the best technology currently available" so that DRMS "insure[s] <br />that society and the environment are protected from the adverse effects" of mine operations. <br />Regulations of the Colorado Mined Land Reclamation Board for Coal Mining Section 4.01.1(5), <br />(9) (revised September 14, 2005). <br />B. DRMS Should Consider Requiring The Mine To Flare Methane. <br />In order to address this significant source of methane pollution, DRMS should consider <br />requiring the Mine to flare vented methane. Although CO2 resulting from the combustion of <br />fossil fuels is often cited as the leading cause of global warming pollution, release of raw <br />methane has a greater than twenty-fold impact on the climate. The Forest Service's EIS <br />recognizes that "flaring may be used to reduce green house gas emissions." Exhibit 1 at 44. <br />Further, flaring of methane could occur safely. According to an October 26, 2007 e-mail from <br />Erik Sherer, a mining engineer with the Division of Safety at the MSHA: <br />There is a long and safe history of flaring waste gas and volatile hydrocarbons in <br />the petroleum and chemical industries. MSHA would approve flaring of <br />methane drainage if appropriate protections are incorporated into the <br />flaring system. <br />See email of Hubert E. Sherer, MSHA to Liane Madsen, USFS, et al. (Oct. 26, 2007 3:12 PM), <br />included in Exhibit 5 (emphasis added). Additionally, in a November 1, 2007 e-mail, Mr. Sherer <br />responded to the EPA'.s comments suggesting that the Mine flare methane. Mr. Sherer stated: <br />MSHA would approve a methane flaring system that incorporates adequate <br />protections to prevent a flame or explosion from propagating to the coal mine.... <br />MSHA has no regulation or policy that prohibits the flaring of methane.... <br />MSHA has reviewed the EPA flare system and concurs that this is an acceptable <br />method for flaring methane produced from coal mine degas holes. However, any <br />proposed flare system would have to be designed for mine-specific conditions <br />(flow rates, gas concentrations, etc.) and must be approved in the ventilation plan. <br />See email of Hubert E. Sherer, MSHA to Liane Mattson, USFS, et al. (Nov. 1, 2007 4:31 AM), <br />included in Exhibit 5. <br />6 Written Testimony of Bradley Udall, Director, NOAA-University of Colorado Western <br />Water Assessment, Hearing on Impact of Climate Change on Water Supply and Availability in <br />the United States before the Subcommittee on Water and Power, Committee on Energy and <br />Natural Resources, U.S. Senate, June 6, 2007. <br />5