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5 <br />Table 5-1 <br />DEIS Comments and Responses <br />Commenter Comment Comment/Response <br /> <br /> wintering big game must not be waived. The amount of methane that would <br /> be released into the atmosphere must be disclosed, along with methods of <br /> reducing the amounts released. <br /> RESPONSE: See all responses to Colorado Wild, et al. <br />Rocky Mountain 1 The DEIS contains inadequate analysis and assessment demonstrating the <br />Clean Air Action proposed coal gas drainage will comply with fundamental state and federal <br />(comment Clean Air Act requirements. Furthermore, all indications are that the coal <br />received 5/9/07- drainage will, in fact, violate Clean Air Act requirements if allowed to <br />after comment proceed as proposed. <br />period, no appeal RESPONSE: See subsequent Rocky Mountain Clean Air Responses. <br />standing) <br />Rocky Mountain 2 The USFS has also failed to analyze and assess the degree to which the <br />Clean Au Action proposed methane venting will affect global warming, in violation of the <br />(comment agency's duties under the National Envirorunental Policy Act ("NEPA"). Our <br />received 5/9/07- concerns follow. <br />after comment RESPONSE: Additional information has been added to the FEIS regarding <br />period, no appeal contribution of greenhouse gases (see Chapter 3, Air Quality) <br />standing) <br />Rocky Mountain 3 No Analysis of Drainage Emissions <br />Clean Air Action Nowhere in DEIS is there any analysis of the air pollutant emissions that will <br />(comment stem from the 168 coal gas drainage wells, which according to the DEIS are <br />received 5/9/07- projected to operate over a 12-year period. This is a significant omission for <br />after comment several reasons. <br />period, no appeal First, the DEIS notes that not just methane will be released into the air as a <br />standing) result of the 12-year drauiage. On page 11, the DEIS states, "[V]enting of <br /> hydrocarbon gases...may affect air quality[.])" Hydrocarbon gases include <br /> volatile organic compounds ("VOCs") besides methane, many of which are <br /> listed hazardous air pollutants under section 112 of the Clean Air Act and <br /> most all of which are regulated as ozone precursors. See, 40 CFR § 51.100(s) <br /> and 40 CFR § 52.21(b)(1)(ii). <br /> Indeed, U.S. Geological Survey studies of coal gas in the Mesaverde Group <br /> have found that, although methane is the primary constituent, "Heavier <br /> hydrocarbon gas content ranges from 0.1 to almost 18 percent[.]."~ This is <br /> particularly the case for coals in the Piceance Basin, which include those in <br /> the Paonia-Somerset coal field.2 While heavier hydrocarbons in the <br /> Mesaverde Group include ethane, they also may include other alkanes like <br /> propane, pentane, and hexane, as well as other hydrocarbon groups including <br /> alkenes, aldehydes, and benzene and benzene derivatives, all of which are <br /> regulated VOCs under the Clean Air Act. See, 40 CFR § 51.100(s). <br /> The best available scientific data on the composition of Piceance Basin coal <br /> gas reasonably indicates that regulated VOCs will be vented into the air. <br /> Indeed, the DEIS neither presents nor references any information or analysis <br /> suggesting or implying otherwise. This omission is a significant error and <br /> shows the USFS has failed to ade uatel anal ze and assess the air uali <br /> <br />C~ <br />• <br />184 Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS <br />