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2008-07-01_REVISION - C1980007
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2008-07-01_REVISION - C1980007
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Last modified
8/24/2016 3:33:56 PM
Creation date
11/20/2008 11:57:21 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
REVISION
Doc Date
7/1/2008
Doc Name
Memorandum of Mountain Coal Company in Opposite to Request for Relief
From
DRMS
Type & Sequence
TR111
Media Type
D
Archive
No
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The EIS examined the potential environmental consequences of the venting of CMM <br />from the proposed MDWs. The EIS quantified the expected amount of CMM to be released, and <br />discussed the heat trapping qualities of methane. The Forest Service then concluded that the <br />state of climate science did not permit the agency to estimate the specific effect of the release of <br />CMM from the West Elk Mine on global or local climate, because emissions from the mine are <br />such a tiny fraction of overall releases of greenhouse gases. As required by NEPA, the Forest <br />Service documented where limitations in current knowledge prohibited further estimation of the <br />effects of emissions. See Final EIS at 59-62, 187-194 (available online, see footnote 1). <br />As part of the EIS, the Forest Service also examined whether there were alternatives to <br />MDWs as a means of controlling CMM, including whether the methane could be burned in <br />surface flares, or captured and put to beneficial use. See Exhibit 3, Final EIS at S-11. After <br />consulting with MSHA, the Forest Service concluded that flaring was an unproven technology <br />posing potential safety hazards. See Exhibit 1, ROD, Mar. 7, 2008 at 10, app. D; Exhibit 4, Davis <br />Letter. The Forest Service further concluded that capturing the methane was also not presently <br />feasible for a variety of reasons, including (1) capture could not occur until the methane was <br />leased, (2) surface disturbance associated with construction of pipelines and other infrastructure <br />posed significant issues in and around surface roadless areas, and (3) uncertainties regarding the <br />quality and quantity of the gas made the economics of any capture system highly questionable. <br />Consequently, the Forest Service eliminated both of these alternatives from detailed study. See <br />Exhibit 3, Final EIS at S-11; Exhibit 1, ROD, Mar. 7, 2008 at 10. <br />Appellants3 filed an administrative appeal of the EIS and draft ROD, raising the same <br />arguments they are now raising to the Board, as well as additional arguments they have not <br />raised to the Board. In particular, Appellants argued that the Forest Service should more <br />completely analyze the flaring and capture options. Regarding flaring, Appellants cited the <br />identical passages from MSHA staffer Hubert E. Sherer that are referenced and attached to <br />Appellants' Request, regarding the possibility that flaring could be approved. The Forest Service <br />concluded that indeed there were some potentially conflicting statements from MSHA on this <br />issue, and the Forest Service's internal appeal decision officer remanded the ROD for <br />a A copy of the Record of Decision dated November 7, 2007 is available at http://www.fs.fed.us/r2/gmug/policy/ <br />minerals/deer_creek/ESeamROD08Nov2007.pdf. <br />s Including some additional organizations not participating in this proceeding. <br />4842-4129-1266\7 3
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