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Appeal Deciding Officer <br />13 <br />parent lease, continued use of coal fired power plants around the United States and other <br />countries, and coal transportation to places where coal is used. <br />EA, 3.2, Environmental Consequences Proposed Action, Greenhouse Gases, page 52, <br />Gaseous emissions in the form of methane from methane drainage wells and other <br />ventilation activities would continue on parent lease and other leases but not on the <br />lease modification as during the mining of coal in the lease modification from all systems <br />including: vertical wells /gob vent boreholes (MDWs) and main mine fans. No new <br />methane drainage wells will be needed for mining this lease modification area. <br />EA, Comparison of Alternatives, Air Quality, Table 2.3: <br />The Proposed Action - same as No Action Alternative except duration extended 2 days to <br />3 weeks based on additional quantity of coal in lease modification. <br />No Action - continued release of methane and other permitted /regulated pollutants at <br />current rates from parent and other leases and private lands. <br />Specifically, the Appellant claims the following alternatives for limiting greenhouse gas <br />emissions were not adequately considered: methane flaring, ventilation air methane (VAM) <br />oxidation, methane capture and use, and carbon credits. <br />The Appellant brought forward these mitigation measures during the comment period. All of the <br />suggested mitigation measures would be effective in reducing GHG emissions. However, none <br />of these potential mitigations can occur on the lease modification area, and it is extremely <br />unlikely that these would occur on leases already analyzed and issued under the North Fork Coal <br />EIS (Tabs 4 and 5) and in the parent lease of 2000. On NFS lands, a stipulation requires no <br />surface occupancy for exploration, methane drainage, or ventilation and /or escape shafts in the <br />Elk Creek coal mining area. The North Fork Coal EIS addressed surface methane venting <br />through gob vent boreholes <br />EA, 3.2, page 47, GHG Possible Mitigations for All Alternatives: <br />Direct mitigations for the release of methane, as brought forward by environmental <br />groups during the comment period, include either flaring, capturing methane and putting <br />to beneficial use or ventilation air methane capture. All would be very effective in <br />reducing greenhouse gas emissions. None of these potential mitigations would occur on <br />the lease modification (as surface use is not permitted) and it is extremely unlikely that <br />these would occur on leases analyzed and issued under the North Fork Coal EIS and <br />issued in 2000 (parent lease COC- 61357) which addressed surface methane venting <br />through gob vent boreholes. However, they may occur on other pending leases or on <br />OMLLC's private lands. <br />Further, since methane is not regulated, nor have any standards been promulgated by <br />EPA, the federal agencies (BLM, Forest Service, OSMRE, MSHA, MMS and EPA) and <br />state agencies with delegated authority (DRMS and CDPHE) operating within their <br />jurisdiction in the federal coal program cannot currently require flaring or capture as a <br />mitigation measure on a previously pproved lease. This situation is currently under <br />review by many State and Federal Agencies and may change based on new regulations or <br />