2008-06-09_REVISION - C1980007 (3)

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Air • • i foreseeable significant adverse effects when there is incomplete or unavailable information. Based on the analysis above, the limited contribution of CO2 equivalent (1.3 percent of the emission in Colorado from fossil fuel combustion annually for 12 years (not considering the likely increase in statewide emissions over that period) would not be considered a significant effect on the human environment. I~owever, the four factors that must be disclosed are discussed below. 1) Information to evaluate the impacts of this project on global warning is incomplete or unavailable. There are no models that can calculate the amount of global warming (if any) that would occur due to this alternative, nor is there scientific research. that can be used to estimate the effects. 2) It is unlikely that the incomplete and unavailable information is relevant to evaluating reasonably foreseeable significant adverse impacts because the impacts would likely not be significant as stated above. 3) There is no credible scientific evidence with which to evaluate the potential impacts related to methane drainage associated with this project. To quote this section (40 CFR 1502.22(b) (4) "For the purposes of this section, 'reasonably foreseeable' includes impacts which have catastrophic consequences, even if their probability of occurrence is low, provided that the analysis of the impacts is supported by credible scientific evidence, is not based on pure conjecture, and is within the rule of reason." Direct mitigation of the release of methane through either flaring or capturing methane and putting to beneficial use would be very effective in reducing greenhouse gas emissions. Flaring is not a method approved by NISHA. Methane is a federal mineral subject to gas lease terms and is not possible to put to beneficial use at the time this document is being prepared as the gas is not under lease. See Alternatives Considered But Eliminated F~°onz Detailed Study in Chapter 2 for further discussion of these concepts. Offset mitigation of the release of methane is not reasonable. For example, to offset the COz equivalent by carbon sequestering through tree planting would require planting 1.7 million trees over 6,000 acres of previously unforested land. Or perhaps replacing 545,000 100-watt light bulbs with 15-watt compact florescent bulbs, or replacing 165,000 gas-powered sport utility vehicle drivers with a hybrid vehicle. In 2002, there were 634,600 registered sport utility vehicles in Colorado, one for every 5 licensed drivers (US Census Bureau 2002).. Class 1 Airshed The Class 1 airshed (West Elk Wilderness) is 10 miles from the project area and there would be no effects on the Class 1 airshed from proposed activities. Alternative 3 Gas quantity released may be slightly less (an estimate of perhaps 15% less than Proposed Action based on tons of coal that may not be mined) due to the shortened panels and fewer MDWs or relatively equal if venting is occurring in some other manner such as re- establishing ahorizontal system and continued use of main mine fan if technological advances (which may not result in any additional FS concurrence or NEPA) to sufficiently to permit optimal venting without vertical vent holes (MDWs) in those areas. However, the effects would be the same as Alternative 2 with regard to not exceeding any current air quality standards and would increase potential greenhouse gas emissions in Colorado from. fossil fuel combustion by approximately 1.1 percent (calculated as CO2 equivalent). Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS 61