2008-06-09_PERMIT FILE - C1980007 ‎(6)‎

• Permit No: C1980007
• IBM Index Class Name: Permit File
• Doc Date: 6/9/2008
• Doc Name: Exhibit 79 Part 2
• Section_Exhibit Name: Exhibit 80 Drilling Activities - TR111
• Media Type: D
• Archive: No

Response to Comments

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Table 5-I
DEIS Comments and Responses
Commenter Comment Comment/Response

impacts on species were published since January, 2003. This highlights the
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importance of utilizing current research to meet NEPA's scientific integrity
requirement.' 3
In this case, though, the USFS has not used any research and has instead
summarily dismissed the global warming impacts related to the methane
drainage as anon-significant issue. The USFS has failed to take a hard look at
both the affected enviromnent and the enviromnental effects surrounding this
project.
We are further concerned that the USFS has not addressed the cumulative
global warming impacts that will occur as a result of future coal burning. Coal
from the mine is produced to fuel coal burning power plants, which will in
turn release harmful carbon dioxide and further contribute to global warming.
This connected action must be addressed by the USFS to ensure the agency
takes a "hard look" at the cumulative impacts of the proposed project.
RESPONSE: 40 CFR § 1502.24 fully states" Agencies shall insure the
professional integrity, including scientific integrity, of the discussions and
analyses in environmental impact statements. They shall identify any
methodologies used and shall snake explicit reference by footnote to the
scientific and other sources relied upon for conclusions in the statement. An
agency may place discussion of methodology in an appendix." There are no
studies which could show definitively what effect this project, or any similar
project, would have on global warning and the Forest Service would be
lacking in expertise to assert such conclusions. MCC voluntarily reports its
emissions of methane vented to EPA, as methane as is not currently regulated
(no regulations or standards exists). The Forest Service, additionally, does not
maintain or collect baseline data on a global scale for climate change and
atmospheric gasses which is required to make any sort of conclusions.
Further, 40 C.F.R. § 1502.1 states "It shall provide full and fair discussion of
significant environmental impacts and shall inform decisionmakers and the
public of the reasonable alternatives which would avoid or minimize adverse
impacts or enhance the quality of the human enviroiunent." The Forest
Service believes that climate change, while it is a global issue, catmot be
measured in terms of effects specific to this proposal, and is therefore a non-
significant issue in terms of this analysis. Levels of methane anticipated to be
released from this project have been disclosed in the FEIS (Chapter 3, Air
Quality). No alternatives have come to light based on this discussion of
climate change, that would alter the proposed action or the purpose and need
behind it, nor is this project establishing policy regarding methane reporting
or establishing any standards, regulations or precedents.
Likewise, the effects on global warming of burning of coal, mined by MCC,
which is shipped to various places and combined with other coal reserves in
other states and regions, can not be discussed more specifically than the effect
of the methane drainage as discussed above due to a lack of scientific studies
documenting the correlation between the amounts of COQ likely to be emitted
b bunun the coal which could be safel mined due to this ro'ect and global
Deer Creek Ventilation Shaft and E Seam Methane Drainage Wells FEIS
193