Mandatory Greenhouse Gas 

Reporting Rule: EPA's Response 

to Public Comments 

Volume No.:45 

Subpart FF—Underground Coal 

Mines 
June 2010 

Subpart FF—Underground Coal Mines 

U. S. Environmental Protection Agency 

Office of Atmosphere Programs 

Climate Change Division 

Washington, D.C. 
iii

FOREWORD 

This document provides EPA’s responses to public comments on EPA’s Proposed Mandatory 

Greenhouse Gas Reporting Rule. EPA published a Notice of Proposed Rulemaking in the 

Federal Register on April 10, 2009 (74 FR 16448). EPA received comments on this proposed 

rule via mail, e-mail, facsimile, and at two public hearings held in Washington, DC and 

Sacramento, California in April 2009. Copies of all comments submitted are available at the 

EPA Docket Center Public Reading Room. Comments letters and transcripts of the public 

hearings are also available electronically through http://www.regulations.gov by searching 

Docket ID EPA-HQ-OAR-2008-0508. 

Due to the size and scope of this rulemaking, EPA prepared this document in multiple volumes, 

with each volume focusing on a different broad subject area of the rule. This volume of the 

document provides EPA’s responses to significant public comments received for 40 CFR Part 

98, Subpart FF—Underground Coal Mines. 

Each volume provides the verbatim text of comments extracted from the original letter or public 

hearing transcript. For each comment, the name and affiliation of the commenter, the document 

control number (DCN) assigned to the comment letter, and the number of the comment excerpt is 

provided. In some cases the same comment excerpt was submitted by two or more commenters 

either by submittal of a form letter prepared by an organization or by the commenter 

incorporating by reference the comments in another comment letter. Rather than repeat these 

comment excerpts for each commenter, EPA has listed the comment excerpt only once and 

provided a list of all the commenters who submitted the same form letter or otherwise 

incorporated the comments by reference in table(s) at the end of each volume (as appropriate). 

EPA’s responses to comments are generally provided immediately following each comment 

excerpt. However, in instances where several commenters raised similar or related issues, EPA 

has grouped these comments together and provided a single response after the first comment 

excerpt in the group and referenced this response in the other comment excerpts. In some cases, 

EPA provided responses to specific comments or groups of similar comments in the preamble to 

the final rulemaking. Rather than repeating those responses in this document, EPA has 

referenced the preamble. 

While every effort was made to include all significant comments related to 40 CFR Part 98, 

Subpart FF—Underground Coal Mines in this volume, some comments inevitably overlap 

multiple subject areas. For comments that overlapped two or more subject areas, EPA assigned 

the comment to a single subject category based on an assessment of the principle subject of the 

comment. For this reason, EPA encourages the public to read the other volumes of this 

document with subject areas that may be relevant to 40 CFR Part 98, Subpart FF—Underground 

Coal Mines. 
iv

The primary contacts regarding questions or comments on this document are: 

 Carol Cook (202) 343-9263 

 U.S. Environmental Protection Agency 

 Office of Atmospheric Programs 

 Climate Change Division 

 Mail Code 6207-J 

 1200 Pennsylvania Avenue, NW 

 Washington, D.C. 20460 

 ghgreportingrule@epa.gov 
v 

TABLE OF CONTENTS 

Section Page

1. DEFINITION OF SOURCE CATEGORY........................................................................ 1 

2. REPORTING THRESHOLD............................................................................................. 6 

3. SELECTION OF PROPOSED GHG EMISSIONS CALCULATION AND 

MONITORING METHODS.............................................................................................. 6 

4. DETAILED GHG EMISSION CALCULATION PROCEDURES/EQUATIONS IN 

THE RULE....................................................................................................................... 12 

5. MONITORING AND QA/QC REQUIREMENTS ......................................................... 12 

6. DATA REPORTING REQUIREMENTS........................................................................ 16 

7. COST DATA.................................................................................................................... 16 

8. OTHER SUBPART FF COMMENTS............................................................................. 19 
SUBPART FF—UNDERGROUND COAL MINES 

1. DEFINITION OF SOURCE CATEGORY 

Commenter Name: Craig Holt Segall 

Commenter Affiliation: Sierra Club 

Document Control Number: EPA-HQ-OAR-2008-0508-0635 

Comment Excerpt Number: 50 

Comment: Coal mines are a significant source of methane, emitting on the order of 58.5 

MTCO2e annually. Collecting and making public accurate information concerning methane 

emissions from mines is particularly important because at least one federal agency has taken the 

position that such data, when supplied by the mine, is proprietary, confidential, and cannot be 

publicly released. We agree with EPA that the use of the Mine Safety and Health Administration 

thresholds, which capture more facilities and a greater quantity of emissions than EPA’s usual 

emissions thresholds, is an appropriate step. [footnote: 291 See U.S. Forest Service, Final 

Environmental Impact Statement, Deer Creek Shaft and E Seam Methane Drainage Wells 

Project (Aug. 2007) at 60 (“Quarterly reporting of methane emissions [from the West Elk 

underground coal mine] to BLM is considered confidential information and cannot be released 

by the Forest Service.”) (available at 

www.fs.fed.us/r2/gmug/policy/minerals/deer_creek/Deer_Ck_Shaft_and_ESeam_MDW_Project

_ FEISr2.pdf) (Ex. 45).] EPA opted not to include abandoned coal mines in this reporting rule. 

While we understand that identifying the operators of these mines may be difficult, we do not 

support this wholesale exclusion, and particularly not with regard to mines that will become 

abandoned in the future. Abandoned – that is, closed – mines are a significant methane source, 

producing 5.4 MT CO2e annually according to EPA. A 2004 EPA Coalbed Methane Outreach 

Program report likewise documents significant emissions from the relatively small subset of 

abandoned mines that are ‘gassy. Although that report suggests such emissions may decline in 

the future, as older gassy mines will finish outgassing and newer mines tend to contain less 

methane, the problem will nonetheless remain for quite some time.[footnote: See EPA Coalbed 

Methane Outreach Program, Methane Emissions from Abandoned Coal Mines in the United 

States: Emission Inventory Methodology and 1990-2002 Emissions Estimates. (Apr. 2004) (Ex 

46).] We therefore suggest EPA take two steps to monitor such sources: First, for existing 

abandoned mines whose operators can be identified from state or federal records, we recommend 

that EPA require the installation of appropriate monitoring equipment. While we recognize that 

not all such mine operators may be identifiable, those that are, and which remain in business, 

should be required to account for the continuing emissions associated with their past mining 

activities. Second, EPA should make clear that the abandoned mine exception does not apply 

prospectively. There is no reason to allow operating mines to escape monitoring simply because 

they are no longer producing. Consistent with the ‘once-in, always-in’ policy that motivates the 

reporting rule generally, EPA should require all covered coal mines to continue reporting, 

whether or not they have been closed or abandoned. This reporting should include the period of 

post-mining activities. Surface mining typically occurs on relatively un-gassy seams, but surface 

mines as a whole account for 24% of all coal mine emissions. Because emissions from surface 

mines – which occur along the entire seam surface, rather than from well-defined emissions 

1 
points – are more difficult to measure, EPA has excluded the category entirely. This exclusion 

should not continue indefinitely. As EPA acknowledges in the TSD for coal mines, the IPCC has 

developed monitoring methods for surface mines. EPA has also developed such methods, which 

are based upon basin-specific emission factors for coal produced from such mines. EPA has 

promoted an example surface mine where the operator has successfully captured methane 

emissions and converted it to energy to be sold. [footnote: See U.S. EPA, SURFACE COAL 

MINE METHANE RECOVERY PROJECT OPPORTUNITIES 11 (July 10, 2008) (EPA ID 

430R08001), http://www.epa.gov/coalbed/docs/cmm_recovery_opps_surface.pdf (listing mines 

estimated to emit half of surface mine methane emissions in the U.S., discussing North Antelope 

Rochelle Mine as already having a methane capture operation in place) (Ex 48).] Where capture 

could work, estimation or measurement should at least be possible. While, as EPA observes, 

these methods presently may not be robust, they are likely better than simply excluding the 

sector. EPA should consider requiring these methods for surface mines and adjusting emissions 

figures appropriately to account for uncertainty. Whether or not EPA employs the existing rough 

methodologies, however, it should work aggressively to include this significant methane source. 

Emission factor approaches could, for instance, be refined by developing site-specific factors for 

each mine. Fenceline measurement techniques like DIAL and SOF could also be employed. We 

urge EPA to support work in this area and to regularly reevaluate opportunities to include 

accurate surface mine methane measurements in the rule. 

Response: EPA agrees with the commenter that the use of the Mine Safety and Health 

Administration thresholds is appropriate.

For information on the treatment of confidential business information in the reporting rule, 

please see the preamble signed in 2009, and also “Mandatory Greenhouse Gas Reporting Rule: 

EPA’s Response to Public Comments, Legal Issues.” 

EPA disagrees with the commenter on the inclusion of abandoned mines in the reporting rule. 

For more information, see today’s preamble section on Subpart FF. 

With respect to the comment on the IPCC methodology, we agree with the commenter. Both the 

EPA and the IPCC have developed emissions estimation methodologies for abandoned 

underground mines for emissions inventory purposes (See the Technical Support Document for 

this sector in the Docket for this Rulemaking). The IPCC methodology is based on the elapsed 

time since abandonment, the mine's initial gassiness, and the extent to which the mines have 

become flooded. Similarly, the EPA methodology is based on the time since abandonment; gas 

content and adsorption characteristics of coal, CH4 flow capacity of the mine; mine flooding; the 

presence of vent holes, and mine seals. Both methodologies are designed to estimate national 

emissions, and recommend default assumptions and approaches for calculating emission factors 

for abandoned underground and surface mines and the portion of mines that are gassy. The 

application of these current methodologies is not suitable for facility-level calculations. 

With regard to the applicability of the “once in, always in” provision of the reporting rule to 

Subpart FF, see today’s preamble section on Subpart FF. 

2 
EPA disagrees with the commenter on the inclusion of surface mines in the reporting rule. The 

application of current methodologies is not suitable for facility-level calculations. Surface 

mining emissions estimates for the U.S. inventory are also developed by using basin-specific 

coal production multiplied by a basin-specific emission factor. Emission factors for surface 

mined coal were developed from the estimated in situ CH4 content of the surface coal in each 

basin. For more information, see today’s preamble section on Subpart FF. 

Commenter Name: James A. Kiger 

Commenter Affiliation: Oxbow Mining, LLC 

Document Control Number: EPA-HQ-OAR-2008-0508-0810.1 

Comment Excerpt Number: 2 

Comment: Measurement Accuracy As noted in the proposed rules, accuracy of methane 

measurements may be variable based upon the technique that is used to obtain measurements. 

Even the most accurate instrumentation will have accuracy difficulties based upon varying 

conditions, especially in remote locations. Elevation, atmospheric pressure changes, daily 

temperature fluctuations all have influence upon electronic instrumentation which may cause 

calibration problems and therefore call into question the accuracy of the measurements. These 

influences also affect the accuracy of air quantity measurements by affecting the ambient air 

density. Therefore, as with surface mines, etc., due to the difficulties associated with obtaining 

accurate measurements, methane wells should also be exempt. Using variable and often 

inaccurate methane measurements as a foundation for future regulation will only cause future 

problems. 

Response: EPA does not agree with the commenter that CH4 degasification wells should be 

exempt. For more information, see today’s preamble section on Subpart FF. For information on 

EPA’s rationale for excluding surface mines, see today’s preamble and response to comment 

EPA-HQ-OAR-2008-0508-0635, excerpt 50. 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 41 

Comment: Many NMA members currently recover liberated CH4 for various purposes, 

including destruction. CH4 that has been recovered is no longer an emission as it is not vented 

into the atmosphere. NMA recommends that EPA contemplate not including recovered CH4 in 

the reporting requirements. This is practical in light of EPA’s proposed requirements for 

reporting CO2 emissions produced during CH4 destruction processes. 

Response: EPA agrees that CH4 that has been recovered and combusted is not an emission. The 

threshold for coal mine methane is an actual emissions threshold. Therefore, emissions from coal 

mines with CH4 recovery are likely to be lower than from mines that do not have CH4 recovery, 

3 
and if emissions are below the threshold as a result of this recovery, such mines will not be 

required to report. For more information, see today’s preamble section on Subpart FF. 

Commenter Name: D. Lawrence Zink 

Commenter Affiliation: Montana Sulphur & Chemical Company Inc. (MSCC) 

Document Control Number: EPA-HQ-OAR-2008-0508-0505.1 

Comment Excerpt Number: 19 

Comment: How is land management dealt with? Major sources of CO2e arise cumulatively 

from these activities on lands owned by public and private entities. How can fair or effective 

climate change policy be developed by looking at only a small portion of the emissions? For 

example: 1. Controlled production and burning of vegetation/wastes on lands managed by 

numerous entities public and private, producing large volumes of anthropogenic CO2, methane 

and soot from actively managed or cropped lands. 2. Land management practices, including 

wilderness and parkland, allowing and promoting the propagation of range and forest fire fuels 

and the inevitable resultant fires -- producing large volumes of anthropogenic CO2 and soot. 3. 

Coal seam fires and methane releases allowed on and under lands not presently engaged in coal 

mining or CBM development. 4. Coal seam fires and methane releases on and under lands 

engaged in mining of coal or CBM development. 5. Wetlands management and policy affecting 

both public and private lands, and tidal areas, actively encouraging the preservation and/or 

expansion of the generation and release of methane and CO2 gases. If the premise is accepted 

that the effects of these gases is global, enduring, and `climatic’ rather than local, then it makes 

no sense from a health and welfare perspective to distinguish between large, concentrated, 

sources, vs. numerous small sources or large diffuse sources. A pound of CO2 or methane 

emitted from a campfire, ranch, or swamp is as potent (or impotent) as a pound emitted from the 

largest cement kiln or forest fire. Better to account for these emissions from major commercial 

carbon-based fuels one time at the commercial source(s) (or point of importation) of those fuels, 

and to account for non-commercial and non-fuel emissions by special type (wetland, landfill, 

sewage plant, septic tank, coal seam, cement kiln, head of livestock, etc.), and to account for 

sequestration, heat-efficiency, conservation, and reduction successes through direct incentives 

for "above average" performance that will encourage both innovation and voluntary reporting. 

Response: See the section of the preamble signed in 2009 containing responses on source 

categories to report. Reporting is not required for coal seam fires; no methodology is provided in 

the rule. Coal seam fires, whether associated with coal seams not presently being mined, or those 

that are being mined, are not normal industrial operations. Moreover, simple, accurate and cost 

effective ground-based approaches that mine operators could easily implement to estimate 

emissions from coal fires have not been developed. (See USGS Fact Sheet entitled “Emissions 

from Coal Fires and Their Impact on the Environment,” USGS Fact Sheet 2009–3084, 

September 2009 (http://pubs.usgs.gov/fs/2009/3084/pdf/fs2009-3084.pdf). 

Regarding reporting of emissions from mines no longer actively mining, see today’s preamble 

section on Subpart FF. 

4 
For information on the rationale for excluding certain biological process emissions sources and 

sinks from the rule, and the rationale for thresholds selected for the rule, see the preamble signed 

in 2009, and response to comment EPA-HQ-OAR-2008-0508-0956.1, excerpt number 5 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 11 

Comment: The proposed reporting rule would require facilities to monitor and report emissions 

every year once a facility produces emissions over the applicable threshold. NMA believes that 

the lack of flexibility exhibited by the "once-in, always-in" requirement of the proposed 

reporting rule will eliminate incentives for mining operations to reduce GHG emissions. 

Additionally, such a provision will be in appropriately burdensome for mining operations that 

dramatically reduce, postpone or eliminate production activities from year to year following 

spikes in production or one-time activities that are especially typical in certain aspects of mining. 

This also penalizes proactive companies that take measures to reduce emissions but are still 

required to report. For instance, NMA recommends that reporting should not be required in years 

when production decreases dramatically, mills or beneficiation circuits shut down, or other 

factors cause emissions to drop below the ultimate reporting threshold (i.e. 25,000 - 100,000 mt 

CO2e per year). This would be accomplished for coal suppliers by applying the final reporting 

threshold to surface and underground coal mining operations. NMA supports EPA specifically 

recognizing that requiring continued monitoring from closed underground coal mines is 

inappropriate. NMA believes, however, that applying continued reporting requirements to other, 

non-coal mining operations is similarly inappropriate, and should be made consistent with EPA’s 

approach for underground coal mines. Perpetual reporting can lead to irreconcilably misleading 

comparisons that will not be useful in informing policy decisions, will be overly confusing, and 

will only result in unnecessary burdens on regulated entities. For reasons stated above, NMA 

also believes that the proposed 25,000 tons CO2e emissions threshold is fairly arbitrary. Once a 

facility exceeds the threshold, for instance, it will be required to report every subsequent year, 

regardless of emissions reductions. A facility that emits 24,500 mt CO2e per year, however, 

could presumably do so annually without ever being required to report. To the extent that EPA 

finalizes a regulation that only requires reporting from facilities that emit in excess of 25,000 mt 

CO2e per year, NMA believes that a better approach would be to release facilities from reporting 

requirements if they demonstrate that emissions fell under the threshold for a certain period of 

time. Given that this regulation, if promulgated, may be of limited duration and that EPA may 

reevaluate the need for this regulatory program after legislative policy decisions are made, NMA 

recommends that if a facility reports below the threshold for two consecutive years, it should no 

longer be subject to reporting obligations. 

Response: See Section II.H of the preamble signed in 2009 for the response on reporting 

frequency and provisions to cease reporting. The final rule does not contain the “once in, always 

in” requirement; see the preamble section (from 2009), “Summary of Comments and Responses 

on Frequency of Reporting and Provisions to Cease Reporting.” Regarding reporting by closed 

mines, see the response to comment EPA-HQ-OAR-2008-0508-0635, excerpt number 50. 

5 
The rule does not require reporting of emissions from surface mines, as discussed in today’s 

preamble section on Subpart FF. 

For information on the rationale for thresholds selected for the rule, see today’s preamble, and 

response to comment EPA-HQ-OAR-2008-0508-0956.1, excerpt number 5. 

2. REPORTING THRESHOLD 

Commenter Name: Kathy G. Beckett 

Commenter Affiliation: West Virginia Chamber of Commerce 

Document Control Number: EPA-HQ-OAR-2008-0508-0956.1 

Comment Excerpt Number: 5 

Comment: As justification for not setting a threshold for coal suppliers, EPA provides that 

mines producing less than 100,000 tons per year can conduct proximate analyses and simplified 

procedures for calculating and reporting imputed emissions. Surface and underground coal 

mining subject to 40 CFR Part 98, Subparts FF, KK, and LL should be subject to the reporting 

threshold that is ultimately established for other industries unless EPA is able to provide valid 

reasons for doing otherwise. Further, establishing the threshold at 100,000 mtCO2e/yr instead of 

the proposed 25,000 level would ensure accurate reporting while sparing small mines and 

manufacturers from the burdens of compliance. 

Response: For information on the reporting threshold, see today’s preamble for Subpart FF and 

the preamble signed in 2009. 

3. SELECTION OF PROPOSED GHG EMISSIONS CALCULATION AND 

MONITORING METHODS 

Commenter Name: Jeff A. Myrom 

Commenter Affiliation: MidAmerican Energy Holdings Company 

Document Control Number: EPA-HQ-OAR-2008-0508-0581.1 

Comment Excerpt Number: 43 

Comment: MidAmerican submits that CEMS should be allowed as a reporting methodology, 

but not required. EPA should also be aware that some mines have such low methane emissions 

that methane emission comprise close to one-millionth of the ventilation air emitted. 

Response: For background information on CEMS requirements and changes in monitoring from 

the proposed rule for this source, see today’s preamble section on Subpart FF. 

6 
Ventilation systems at active underground coal mines exceeding the proposed threshold (i.e., 

where MSHA is already conducting quarterly or more frequent sampling), must only report 

emissions annually, based on the results of this periodic sampling. Where they are currently used 

for ventilations systems, CEMS are allowed, but not required. Mines with rates of methane 

emissions below the defined threshold, as determined by MSHA for mine safety reasons, would 

not have to report. 

EPA has changed the monitoring requirements for methane liberation from degasification 

systems. EPA has reevaluated costs associated with required CEMS use for this methane 

liberation, and has changed the monitoring method to require weekly or more frequent sampling, 

or CEMS. 

The basis for this change was twofold. First, EPA reassessed the number of degasification wells 

and vent holes that would likely be associated with mines required to report under the rule. 

Originally, it was estimated that approximately 200 remote gob gas vent wells/holes do not 

currently monitor degasified gas volumes produced. However, based on the comments received, 

EPA revised its estimate. EPA now estimates that 500 degasification wells are venting methane 

to the atmosphere, and it was also assumed that these wells also had an average 3 year life, 

resulting in an average of 167 new wells that are brought on line each year (as a comparable 

number are retired). This resulted in a substantially larger number of degasification wells that 

would be required to install CEMS systems in compliance with the originally proposed 

requirements, with an associated greater incremental cost burden. 

Second, again based on comments received, EPA determined that implementing CEMS on some 

degasification wells could be quite costly, and in many cases, would be difficult and/or 

impractical due to remote location, unavailability of power, inaccessibility, susceptibility to 

vandalism, and the relatively short longevity of many degasification and vent holes. As a result, 

EPA included consideration of the costs associated with weekly or more frequent sampling, as an 

alternative to the installation of CEMS, to potentially address this potential burden. . However, it 

was assumed that gob gas vent hole wells are much less likely to be currently monitored. 

Therefore, it was determined that these wells would need to incur incremental costs for either 

installing CEMS meters, or for planning and implementing a sampling program. In this regard, 

the costs associated with planning and implementing a weekly sampling program were 

determined to be less burdensome than the costs associated with installing and maintaining 

CEMS. 

For degasification systems where gas is sold, used onsite, or otherwise destroyed, EPA 

determined that such meters are already installed on most of these systems. 

For information on the rationale for thresholds selected for the rule, see the preamble signed in 

2009, and response to comment EPA-HQ-OAR-2008-0508-0956.1, excerpt number 5 

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Commenter Name: Jeff A. Myrom 

Commenter Affiliation: MidAmerican Energy Holdings Company 

Document Control Number: EPA-HQ-OAR-2008-0508-0581.1 

Comment Excerpt Number: 42 

Comment: EPA requests comment on whether relying on MSHA sampling procedures, which 

were developed to ensure adherence to safety standards, is appropriate and sufficiently accurate 

for a GHG emissions reporting program. The EPA are interested in viewpoints on whether 

quarterly sampling is sufficient to account for potential fluctuations in emissions over smaller 

time increments (e.g., daily) from the mine (page 16554). The procedures and quarterly sampling 

are sufficient as an option for GHG emissions reporting from degasification of underground coal 

mines if such data can be received from MSHA. However, EPA should be aware that MSHA 

does not normally report such data back to mines unless requested; thus, data certification from 

the mines may not be appropriate if the data is provided by an external agency that collects the 

data. EPA should also be aware that some mines have such low methane emissions that 

degasification wells, let alone flares, are not needed. 

Response: EPA disagrees that quarterly sampling is sufficient as an option for GHG emissions 

reporting from degasification of underground coal mines. See response to comment EPA-HQOAR-2008-0508-0581.1, excerpt 43. MSHA’s requirement for quarterly sampling is for 

ventilations systems, and does not include degasification systems. EPA is aware that MSHA 

does not normally report sampling data from ventilation systems; for more information, see 

today’s preamble. 

Under the rule, coal mine facilities required to report would report data directly to EPA. Please 

see the preamble signed in 2009 for more information on reporting and certification 

requirements. 

For information on the monitoring requirements for degasification systems, see today’s preamble 

section on Subpart FF, and the response to comment EPA-HQ-OAR-2008-0508-0581.1, excerpt 

43. 

EPA realizes that some mines have low methane emissions. Those with emissions below the 

defined reporting threshold are not required to report. For information on the rationale for 

thresholds selected for the rule, see today’s preamble and response to comment EPA-HQ-OAR2008-0508-0956.1, excerpt number 5. 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 40 

Comment: Many NMA members have no need to employ degasification systems at their 

underground mines. The entirety of liberated CH4 at those operations passes through the 

8 
ventilation system. Many of the mines that do employ degasification systems estimate that the 

vast majority of CH4 (in the case of one company less than 30 percent of the total liberated CH4

from the mine passed through the degasification system) is liberated through the ventilation 

system. NMA believes that, from an industry-wide standpoint, the amount of CH4 that is 

ultimately liberated to the atmosphere through degasification systems is negligible, particularly 

when taken in consideration with the costs and burdens associated with requiring underground 

mines to install continuous monitoring systems on all degasification orifices. NMA believes that 

monitoring and reporting of emissions from ventilation systems in accordance with current 

MSHA procedures is sufficient to provide EPA detailed CO2 equivalency data in furtherance of 

its stated policy objectives. Alternatively, NMA recommends that monthly or quarterly 

measurements of CH4 emissions and air flow rates, depending upon accessibility should be 

substituted for continuous monitoring of degasification wells and vent holes. Electronic flow 

meters and gas analyses need the attention of trained technicians for maintenance and calibration. 

Periodic monitoring, conversely, can be done with portable, hand-held flow meters and CH4

analyzers. Further, detailed chromatography analyses can be run on quarterly samples. This 

would be much more accurate and cost effective than requiring mines to purchase 

chromatographs for every orifice and hiring personnel to operate, monitor and calibrate such 

equipment. 

Response: For information on the rationale for reporting of degasification system methane, see 

today’s preamble section on Subpart FF, and response to comment EPA-HQ-OAR-2008-0508-

0466.1, excerpt 41. 

EPA agrees with the commenter that the monitoring requirements for ventilation systems are 

sufficient for obtaining data for this rule. 

For information on the monitoring requirement for degasification systems, see today’s preamble 

section on Subpart FF, and response to comment EPA-HQ-OAR-2008-0508-0581.1, excerpt 43. 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 38 

Comment: EPA proposes to require all underground mining operations to install continuous 

monitors on all wells and vent holes associated with the facility’s degasification system. 

Continuous monitoring of CH4 emissions and air flow rates for all degasification wells and 

degasification vent holes is not feasible for several reasons. The remote location, unavailability 

of power, inaccessibility, susceptibility to vandalism, and the relatively short longevity of many 

degasification and vent holes renders continuous monitoring impractical. 

Response: See today’s preamble section on Subpart FF and response to comment EPA-HQOAR-2008-0508-0581.1, excerpt 43. 

9 
Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 37 

Comment: NMA endorses EPA’s decision to rely on MSHA sampling procedures for 

monitoring and reporting ventilation emissions. NMA further believes that monitoring 

requirements for ventilation systems will capture the lion’s share of CH4 emissions data from 

underground coal mines. CH4 emissions from portals, shafts, and other openings not already 

included in an air quality permit for criteria pollutants should be excluded from the GHG 

inventory for underground mines. Emissions of this nature should be considered fugitive and not 

subject to regulation or quantification under this proposed rulemaking. We encourage EPA to 

establish, in conjunction with MSHA, a mechanism to ensure the timely and efficient transfer of 

the quarterly sampling results. 

Response: EPA agrees with the commenter on the use of MSHA sampling procedures for 

monitoring ventilation methane. To the extent that “portals, shafts, and other openings not 

already included in an air quality permit for criteria pollutants” correspond to ventilation shafts 

where MSHA sampling takes place, or to degasification vent holes, their CH4 emissions are 

covered. 

EPA is not at this time establishing a mechanism with MSHA to ensure the timely and efficient 

transfer of the quarterly sampling results from MSHA to the operators required to report. 

Owners and operators are responsible for reporting emissions data to EPA. 

For information on the monitoring requirements, see response to comment EPA-HQ-OAR-2008-

0508-0581.1, excerpt 43. 

Commenter Name: Craig Holt Segall 

Commenter Affiliation: Sierra Club 

Document Control Number: EPA-HQ-OAR-2008-0508-0635 

Comment Excerpt Number: 51 

Comment: We generally agree with EPA’s approach to underground coal mine methane 

monitoring, but urge EPA to move towards more accurate direct measurement methods. As EPA 

observes, “[m]any mines sample GH4 daily from ventilation systems” using handheld analyzers, 

and many other mines already use GEMS for this purpose. Yet, EPA opted instead to require 

only quarterly monitoring for methane emissions from ventilation systems, rather than daily, and 

did not even require mines with GEMS to use them to monitor emissions from ventilation 

systems. EPA should not take this lax course. As EPA writes, GEMS use “could increase the 

accuracy of . . . [methane] emissions calculations because it takes into consideration any 

variability in emissions from mining operations that may not be represented in the quarterly 

sampling.” EPA’s failure to require GEMS for underground coal mine ventilation systems is all 

the more puzzling given that EPA is very properly proposing to require GEMS for methane 

degasification wells from such mines – a proposal we strongly support. Simply put, EPA should 

10 
require GEMS use for ventilation systems at underground mines, extending an already widelyfollowed practice. 

Response: For information on the monitoring requirement, see today’s preamble section on 

Subpart FF and response to comment EPA-HQ-OAR-2008-0508-0581.1, excerpt 43.

Commenter Name: Joseph D'Amico 

Commenter Affiliation: Foundation Coal 

Document Control Number: EPA-HQ-OAR-2008-0508-0212.1j 

Comment Excerpt Number: 4 

Comment: Just be careful when you look at your option one, option two, option three for the 

continuous emission monitoring systems. If we had flow rates of 1 million, 2 million, 5 million 

cubic feet a day, oh, sure, you would load it up with instruments, but when you get flow rates 

that have zero in most cases or barometric pressure makes it go the other way -- so that is the 

point. That's all. Keep track of that, and I think you will be better off. You will be better served. 

As I said, wrong information is worse than no information, and that will make you do things. 

Response: See today’s preamble section on Subpart FF and response to comment EPA-HQOAR-2008-0508-0581.1, excerpt 43. 

Commenter Name: Joseph D'Amico 

Commenter Affiliation: Foundation Coal 

Document Control Number: EPA-HQ-OAR-2008-0508-0212.1j 

Comment Excerpt Number: 2 

Comment: Because all underground coal mines are tied to MSHA anyway when it comes to 

reporting, it is always done anyhow with MSHA, but I see here on page 548, there is proposed 

monitoring systems, and you have option one and option two and option three. Option one is the 

default. You say, well, there's so many tons of coal being mined, and you can make an 

association by the gas content, how much methane would have been emitted. You go to option 

two, and it is periodic sampling of methane, and that is basically what MSHA does to keep the 

mine safe. Then there is option three, use of CEMS. That is continuous emissions monitoring 

systems. Now, remember, we are the people out there who are drilling wells with compressors 

and wellheads, bring all that to a gathering system and then to a gas processing plant. So we have 

to know what the gas quality is at each and every one of those wells. We try, as hard as we may, 

to put instrumentation at wellheads that will live in remote locations, and you find yourself going 

back to the other method, which is the periodic sampling, where you take the sample, you bring 

it back to a lab, you have a gas chromatograph analysis, and now you know what you have got, 

because if you try to put instruments in remote locations, you are going to get information -- the 

wrong information is worse than no information. You are better off knowing what you are 

dealing with. As far as flow meters, we generally put electronic mass flow meters that are very 

calibratable. We need to know what that is. That is fine, but that is only at, say, a portion of the 

wells. You could have hundreds of wells -- not necessarily wells. They could be bore holes, 

11 
vents, all kinds of things that we currently monitor for MSHA, and that is where we start. When 

you look out on the horizon, you start with that information that we are reporting to MSHA, and 

then you may see some wells are flowing -- most are not -- and it changes with time. So you 

keep track of that. 

Response: See today’s preamble section on Subpart FF and responses to comments EPA-HQOAR-2008-0508-0581.1, excerpt 43, and EPA-HQ-OAR-2008-0508-0635, excerpt 51. 

4. DETAILED GHG EMISSION CALCULATION 

PROCEDURES/EQUATIONS IN THE RULE 

Commenter Name: Joseph A. D'Amico 

Commenter Affiliation: Foundation Coal Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-0421.2 

Comment Excerpt Number: 7 

Comment: Additional explanation is needed surrounding the definition of “in operation.” 

Variables V and C to Equation FF-2 require the degasification system to report for any time it is 

“in operation.” Please advise as to your reporting requirements on preparatory and testing 

operations, required to ensure safety and accurate functionality. For example: 1. When the lines 

are pigged, the small amount of gas released should not have to be measured as fugitive 

emissions because it may only occur once a year for only a short time (minutes). 2. Additionally, 

any time any of the lines are vented, the small amount of gas should not have to be measured as 

fugitive emissions because it may be a rare occurrence. 3. Lastly, advise as to if the waste gas 

stream from a CH4 recovery system would have to be continuously monitored for quality and 

quantity. 

Response: EPA’s intent is for the sampling of emissions under normal operations. Therefore, 

emissions during pigging or when lines are vented would not be considered part of normal 

operations. 

EPA is requiring continuous monitoring of degasification methane that is combusted, for both 

quality and quantity. Uncombusted CH4 from this gas stream is not directly monitored, but a 

destruction efficiency factor is included in the calculations to account for this CH4 emission. 

5. MONITORING AND QA/QC REQUIREMENTS 

Commenter Name: James A. Kiger 

Commenter Affiliation: Oxbow Mining, LLC 

Document Control Number: EPA-HQ-OAR-2008-0508-0810.1 

Comment Excerpt Number: 3 

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Comment: 1. Due to the remote nature of the borehole sites, power is not available to run the 

instrumentation. 2. MSHA methods of measuring methane gas liberation have questionable 

accuracy. Air quantity readings taken by Inspectors are quite often inaccurate, especially in high 

velocity mine areas. MSHA methods and their accuracies suit the purposes for which they are 

presently used, but do not provide accuracy needed for gathering of scientific data or for 

regulatory purposes. 3. Access to the exhausters, particularly during winter months, will make 

effective operation, maintenance and trouble shooting of the exhauster monitoring equipment 

very difficult. Our area is affected by deep snows with very steep terrain during the winter 

months. Quite often the access to the remote wells is very limited and delayed. 4. The air flow 

volume determination will be adversely affected by the variable density of the associated gasses 

mixed in when there are low methane concentrations. Methane concentrations can vary from 

25% to 90% and be mixed with a variety of other gasses. 

Response: See today’s preamble section on Subpart FF and response to comments EPA-HQOAR-2008-0508-0581.1, excerpt 43, and EPA-HQ-OAR-2008-0508-0635, excerpt 51. 

Commenter Name: Joseph A. D'Amico 

Commenter Affiliation: Foundation Coal Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-0421.1 

Comment Excerpt Number: 4 

Comment: Section 98.324, Monitoring and QA/QC “Requires the use of gas chromatography.” 

As long as quarterly samples are allowable, a gas sample can be sent to a laboratory for a 

detailed chromatography analysis. This would be much more accurate and more cost effective 

than purchasing many chromatographs, hiring and training technicians to run/monitor/calibrate 

them. A portable CH4 gas analyzer that has been calibrated could also be used. 

Response: The requirement for use of gas chromatography can be met by sending a sample to a 

laboratory. 

Commenter Name: Joseph A. D'Amico 

Commenter Affiliation: Foundation Coal Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-0421.1 

Comment Excerpt Number: 2 

Comment: “Degasification” – EPA proposes continuous monitoring for CH4 content and flow 

rates for all degasification wells and/or vent holes. Having done this for the purpose of 

recovering de-gas methane for many years, the following is a list of reasons why it should not be 

mandated as “Continuous” but instead “Periodic – Quarterly” as per MSHA. 1. Very remote well 

sites are difficult to get to. 2. No electricity is available. 3. Electronic flow meters and electronic 

gas analyses need the attention of a trained technician for maintenance and calibration. 4. There 

is a large difference in price and accuracy of CH4 gas analyzers. 5. A better plan would be to 

follow MSHA’s periodic or quarterly flow and CH4 content testing. a. Portable, hand-held flow 

meter and CH4 analyzers can be used quarterly. b. The data from continuous monitors in remote 

13 
areas may be no better than the MSHA periodic data and the added cost of equipment and 

personnel does not warrant it. 

Response: See today’s preamble section on Subpart FF and response to comments EPA-HQOAR-2008-0508-0581.1, excerpt 43, and EPA-HQ-OAR-2008-0508-0635, excerpt 51. 

Commenter Name: Joseph A. D'Amico 

Commenter Affiliation: Foundation Coal Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-0421.2 

Comment Excerpt Number: 1 

Comment: “Degasification” – EPA proposes continuous monitoring for CH4 content and flow 

rates for all degasification wells and/or vent holes. Monitoring should not be mandated as 

“Continuous” but instead “Periodic – Quarterly” as per MSHA. Buildings to house the 

monitoring equipment and electric lines required to operate the equipment require permits that 

may take 6 to 12 months to obtain. 

Response: See today’s preamble section on Subpart FF and response to comment EPA-HQOAR-2008-0508-0581.1, excerpt 43. 

Commenter Name: Fredrick Palmer and Dianna Tickner 

Commenter Affiliation: Peabody Energy 

Document Control Number: EPA-HQ-OAR-2008-0508-0552.1 

Comment Excerpt Number: 5 

Comment: First, EPA requests comments on the commencement date for reporting. 74 Fed. 

Reg. at 16471/1. Peabody recommends the second option set forth by EPA. Peabody does not 

believe that the 2010 date for commencement of reporting is realistic. Even on the most 

expeditious path imaginable, assuming EPA gives due regard to the comments it receives from 

the very large number of entities and sectors to which the proposed regulation applies, the rule 

cannot be made final until the last quarter of 2009. We cannot be ready, therefore, to make the 

investments in equipment, labor and training that will be necessary to comply with the rule by 

January 1, 2010. Moreover, there is likely to be a considerable shortage of laboratory capacity to 

undertake daily ultimate analysis for all or many coal mines exceeding a 100,000-ton per year 

production level. Peabody suggests a January 1, 2011 start date. This is consistent with the fact 

that, at least for coal suppliers, EPA already has the data and tools it needs to analyze CO2

regulatory scenarios, and therefore there is no pressing need for the new data EPA seeks. EPA 

states that the disadvantage of its second option is that it delays receipt by EPA of "critical data, 

even basic data, necessary to inform future policy and regulatory development." Id. That is not 

the case with coal supplier reporting. 

Response: See today’s preamble section II B Changes to the Reporting Schedule.

14 
Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 2 

Comment: EPA proposes to require facilities impacted by this rulemaking to begin monitoring 

requirements January 1, 2010, and to file initial reports by March 31, 2011. Assuming that EPA 

finalizes a reporting rule, it would be optimistic to think that at this late date, impacted entities 

would become aware of the final regulations to which they would be subject prior to the end of 

2009. NMA trusts that EPA will devote adequate time and attention to the comprehensive 

comments it will receive on this proposal, and adjust the rule accordingly to ensure a fair and 

productive program. NMA does not believe that the 2010 commencement date identified in the 

proposal is realistic. NMA recognizes that for a portion of regulated entities that would become 

subject to a finalized proposal, electric generating units subject to the Acid Rain Program for 

instance, existing monitoring and reporting procedures are already in place, and compliance with 

a reporting rule for those entities will be relatively straightforward. Many NMA members that 

will become subject to new regulation, however, will have a much steeper climb in order to 

comply. Given that affected entities will need time to read and understand a final rule, identify 

questions and obtain clarifications, conduct training and implement appropriate monitoring 

programs or install data collection equipment, NMA does not believe that a January 1, 2010, start 

date will offer sufficient time to prepare for the collection of meaningful data. NMA 

recommends that EPA consider requiring regulated entities to begin monitoring January 1, 2011, 

at the earliest. 

Response: See today’s preamble section II B Changes to the Reporting Schedule.

Commenter Name: Robert E. Murray 

Commenter Affiliation: Murray Energy Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-1577 

Comment Excerpt Number: 10 

Comment: This Rule was supposed to be out in September, 2008, yet came out in May 2009. 

This 8-month gap shows the complexity of developing such a Proposed Rule. It will require at 

least the time it took to create the rule as it will to implement it. If EPA had released this Rule on 

time, then perhaps the required monitoring requirements could be realized by the start date of 

January 1, 2010, but as no rule has been finalized as of June 9, 2009, this start date is completely 

unreasonable. As mentioned in the previous section, Murray Energy must custom-order the 

appropriate equipment and hire talented individuals to monitor the mines. The technology barely 

exists in commercialized form and the talent is limited to scholars and scientists, so Murray 

Energy recommends that the start date be pushed back two (2) years to ensure that we can 

purchase and correctly install the proper monitoring equipment, as well as hire adequatelytrained individuals. We do not allow untrained miners into underground coal beds, and this 

philosophy of properly training individuals extends to non-mining personnel as well. As a result 

of our recommended two-year delay in monitoring requirements, we further urge that the date to 

file initial reports be pushed back two years to March 31, 2012. 

15 
Response: See today’s preamble section II B Changes to the Reporting Schedule.

6. DATA REPORTING REQUIREMENTS 

Commenter Name: Joseph A. D'Amico 

Commenter Affiliation: Foundation Coal Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-0421.1 

Comment Excerpt Number: 1 

Comment: “Destroyed CH4 includes flaring thermal oxidation, on-site energy and CH4

conveyed through pipelines (including natural gas pipelines for offsite combustion.” Coal mine 

methane (“CMM”) that has been recovered, purified and conveyed through pipelines should 

have its own category. This is by far the best GHG reduction and energy recovery utilization. a) 

Methane that has been recovered is no longer an emission as it is not vented to the atmosphere, 

but conveyed through a pipeline for direct use, thereby displacing geological natural gas that 

would have been consumed. Therefore, recovered methane should not be included in a coal 

mine’s total emission calculation. b) Recovered CMM that is put into a pipeline is 2.5 times 

more beneficial in reducing GHG emissions than generating electric power. Natural gas engine 

fired power generation is 30-35% efficient while a natural gas fired furnace is 80% efficient. c) 

Recovered CMM that is put into a pipeline may not necessarily be combusted as significant 

portions may go to chemical plants where the CH4 is used to make plastics and other materials 

(~100% Efficiency). Thermal destruction of CH4 is the last thing that should be done, not the 

first. Energy recovery should be first. If we degas properly, there will not be enough methane left 

in the ventilation air to thermally oxidize. We have already witness this at our Western 

Pennsylvania coal mines. a) Thermal destruction of methane using a flare or ventilated air 

methane (VAM) has a 0% thermal efficiency. b) Recovered methane can have energy efficiency 

of 35% - 80%, depending on utilization. 

Response: All recovery of CH4, including through pipeline projects, at coal mines meeting the 

threshold is accounted for under the reporting rule. It is reported, but it is not included in the 

mines’ emissions totals. For more information, see today’s preamble section on Subpart FF and 

response to comment EPA-HQ-OAR-2008-0508-0466.1, excerpt 41. 

7. COST DATA 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 39 

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Comment: The costs of installing continuous monitoring equipment on all degasification wells 

and vents (some mines potentially require over 100 boreholes) will present significant costs to 

NMA members. 

Response: See today’s preamble section on Subpart FF and response to comment EPA-HQOAR-2008-0508-0581.1, excerpt 43. 

Commenter Name: Joseph D'Amico 

Commenter Affiliation: Foundation Coal 

Document Control Number: EPA-HQ-OAR-2008-0508-0212.1j 

Comment Excerpt Number: 3 

Comment: Once you see some that are start flowing, then you go out and you start putting some 

instruments on it. Well, then it comes into what type of instrument. A continuous emission 

monitoring system? I will tell you this, your cost estimates are off by a factor of a thousand when 

you start getting into mass flow meters, electronic analyzers, and chromatographs, for every one 

of those. Think about it, 100 times 10-, 20,000, and then the people to maintain it and run it. You 

are better off doing just what we are doing now and following the MSHA regulations, and you 

can see what is going on and make it happen. At the same time, we get a triple advantage. 

Response: See today’s preamble section on Subpart FF. 

Commenter Name: Robert E. Murray 

Commenter Affiliation: Murray Energy Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-1577 

Comment Excerpt Number: 7 

Comment: EPA omits the time and expenses it will take Murray Energy to purchase and install 

greenhouse gas emissions monitoring equipment. This equipment is extremely expensive and 

always made-to-order. Purchasing mine safety equipment to measure air quality and flow is 

always done on a custom basis for each mine, and EPA assumes that our current equipment 

suppliers can and will produce this equipment. This is highly unlikely. Murray Energy spends a 

considerable amount of money to protect our most valuable asset: our employees. We comply 

with all Mine Safety & Health Administration requirements. We go above and beyond necessary 

safety precautions using innovative technologies and employ a full-time staff to continuously 

train our underground employees as to how to react and respond in a mine fire or explosion. This 

training involves hands-on fire-fighting techniques in simulated disaster situations using hightech equipment, such as our Fire Brigade truck. Adding additional technology requires massive 

investment plus more full-time staff to train others to operate this technology, yet still EPA 

believes our First Year Capital Costs are $0. 

Response: See today’s preamble section on Subpart FF. 

17 
Commenter Name: Robert E. Murray 

Commenter Affiliation: Murray Energy Corporation 

Document Control Number: EPA-HQ-OAR-2008-0508-1577 

Comment Excerpt Number: 9 

Comment: The added cost of compliance on a yearly basis was erroneous in EPA’s 

calculations, as well. EPA estimates this will cost the entire industry $11 million. Murray Energy 

operates 8 of the estimated 1,200+ mines covered by this rule, and our compliance costs (wages, 

insurance, training, routine maintenance, installation of equipment at expanded mines, legal fees, 

certifications, etc.) could cost our company $11 million alone. EPA’s arbitrary threshold for 

CO2e disadvantages companies such as Murray Energy, which must seek legal clarification as to 

how to report because of the Rule’s lack of information. 

Response: See today’s preamble section on Subpart FF for information on changes to 

requirements and associated costs. 

Based on the reporting threshold, EPA determined that ventilation emissions were reported and 

electronically accounted by MSHA for in128 mines in 2006. Of these 114 mines exceeded the 

MSHA threshold of mines liberating more than 100,000 cubic feet of per day from ventilation 

systems, which is equivalent to about 15,000 metric tons CO2e per year. 

Cost estimates for reporting ventilation system emissions were based on the assumption that coal 

mine operators would be required to duplicate the MSHA process of collecting air samples and 

ventilation rates, submitting the samples to a lab for analysis, and developing estimates of 

emissions on their own. This process would require mine operators to purchase sampling 

equipment, train personnel in their use, develop emissions estimates based on the data collected, 

and report the results. If this option is pursued, the operator would have to incur the capital and 

O&M costs involved in purchasing and maintaining the air sampling equipment, and in sending 

air samples to an independent lab for analysis. 

More detail on EPA’s estimates for these costs can be found in the Regulatory Impact Analyses 

performed for this rulemaking, found in the docket (see docket EPA-HQ-OAR-2009-0508). A 

copy o f this document is also available on our website (see

http://www.epa.gov/climatechange/emissions/downloads09/GHG_RIA.pdf). 

Commenter Name: Benjamin Brandes 

Commenter Affiliation: National Mining Association (NMA) 

Document Control Number: EPA-HQ-OAR-2008-0508-0466.1 

Comment Excerpt Number: 1 

Comment: NMA supports EPA’s stated goal of promulgating reporting requirements that 

utilize existing GHG emission estimating and reporting methodologies in order to reduce the 

compliance burden on regulated entities. 74 Fed. Reg. 16,456. NMA is concerned, however, 

that EPA has ignored information that is already available, opting instead to propose reporting 

18 
requirements that, in many cases, will impart unnecessary burdens on mining operations and 

other industries. 

Response: EPA does not agree with the commenter that the rule imposes unnecessary burdens 

on mining operations and other industries. See response to comment EPA-HQ-OAR-2008-0508-

1577, excerpt 9. 

8. OTHER SUBPART FF COMMENTS 

Commenter Name: Joseph D'Amico 

Commenter Affiliation: Foundation Coal 

Document Control Number: EPA-HQ-OAR-2008-0508-0212.1j 

Comment Excerpt Number: 1 

Comment: As you know, when you are mining coal, you have to de-gas to make the mine safe. 

In the past, in the past 100 years basically, we were venting that methane to the sky. So we look 

at that as a waste gas opportunity. Within the last 15 years and the last 6 years for short at 

Foundation Coal, we have been recovering a lot of the underground methane at some of our East 

Coast mines, especially to there up in Southwest Pennsylvania. That is still the beginning. There 

is a long way to go. From a purely science and technology applications point of view and 

economics -- let's talk about the economics -- it is not a home run for economic success. It is 

something we said we should be going after this because it is a source of energy, and most 

recently, of course, it is a greenhouse gas that we can also have a double advantage by doing this. 

The reason it is not an economic advantage, you are literally drilling gas wells in front of a long 

wall mining machine. That is as if you and I drilled the gas well on a railroad track and had the 

train come and take it out. So you won't find that many people around ready to write checks and 

invest in that kind of a business, but because of its double advantage of making the mine safe -- 

triple advantage actually, getting an American source of energy that would have been wasted and 

it's good for the environment because you are capturing and utilizing greenhouse gas. It depends 

on what you do with it. In our case, we are recovering it. It is not pure methane. You have to 

treat it, process it, compress it, make it pure, and because you are on the East Coast, you have 

enough pipelines close by. You can put it into the pipeline for use on the East Coast. This is all a 

good thing to do. 

Response: EPA agrees with the commenter that methane recovery at mines has many 

environmental benefits. The methodologies provided in the rule may encourage the development 

of methane recovery projects at mines potentially affected by the rule. Facilities that calculate 

and report emissions under the proposed rule would be able to recognize the offsets potential of 

their mines, and could be at an advantage over facilities that are not reporting under the proposed 

rule, in that they would already have stringent monitoring and data systems in place to calculate 

baselines and emissions reductions. Further, the accurate reporting of emissions from mines will 

improve the confidence of offset buyers and the environmental community in the ability of these 

project activities to produce accurately monitored and verifiable emissions reductions. 

19