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These communications demonstrate that no regulatory hurdles exist to methane flaring. <br />DRMS therefore should consider requiring the Mine to flare methane. Although a flare system <br />would have to be designed for mine-specific conditions, nothing from the MSHA indicates that <br />this alternative is unreasonable or speculative. <br />C. DRMS Should Consider Requiring The Mine To Capture Methane. <br />DRMS should also consider requiring the Mine to capture methane so that it could be <br />collected. Such an approach would reduce or eliminate vented methane that contributes to global <br />warming and would conserve that methane for use. As the Forest Service noted in its analysis: <br />"[i]f able to be put to beneficial use, the estimated amount of gas that may be released from the <br />E Seam could heat approximately 34,800 to 39,500 homes." Project FEIS at 46. As noted <br />above, EPA has stated that proven technology exists to capture the methane. <br />Use of the released methane, rather than venting (or flaring), would provide at least two <br />benefits to Coloradoans in addition to global warming reduction: 1) commercial sale of the gas <br />provides a revenue source through severance taxes, and 2) offsetting the need for production of <br />an equivalent amount of methane (natural gas) from more traditional sources would reduce <br />impacts on public and private lands, as well as water and air resources. <br />While the Forest Service rejected a "capture and use" proposal, it did so without detailed <br />analysis and is now apparently taking steps to make the capture of methane possible. The Forest <br />Service notes in its Record of Decision (ROD) that the agency has recommended lands involved <br />in the Project for leasing for the purpose of aiding methane capture. The ROD states that "[b]y <br />completing this work, the first critical step to affording potential methane release mitigation is <br />underway." ROD at 9, excerpts attached as Exhibit 2. These steps toward methane-release <br />mitigation demonstrate that, notwithstanding complexities and legal limitations, the Forest <br />Service has laid the framework for methane capture at the Mine. Further, the Forest Service has <br />overcome the legal complexities surrounding leasing coal mine methane in Carbon County, <br />Utah, where the Aberdeen Coal Mine is now leasing and capturing coal mine methane. See <br />Lease Serial No. UTU 85441 (June 1, 2007), attached as Exhibit 6. <br />In conclusion, we urge DRMS to analyze and review the above- and below-ground <br />impacts of MCC's mine expansion in a single permit revision. We also urge DRMS to ensure <br />that it is complying with its environmental protection duties by taking the necessary steps to limit <br />methane emissions from the West Elk Mine. Thank you for your attention to this important <br />matter. We would be happy to meet with you or your staff to discuss our concerns and we look <br />forward to your response. Please call me at (303) 454-3370 if you have any questions in this <br />matter. <br />Sincerely, <br />J r? <br />JeremEyNichols, Director <br />Rocky Mountain Clean Air Action <br />6