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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />19 <br />from Coal <br />(MMTCO2e)62 <br />Oil & Gas <br />Open to Leasing <br />(Acres)63 <br /> <br />871,810 <br /> <br />729,330 <br /> <br />635,190 <br /> <br />871,810 <br /> <br />865,970 <br /> <br />Oil & Gas <br />Closed to Leasing <br />(Acres)64 <br /> <br />44,220 <br />(4.8%) <br /> <br />186,700 <br />(20.4%) <br /> <br />280,840 <br />(30.7%) <br /> <br />44,220 <br />(4.8%) <br /> <br />50,060 <br />(5.5%) <br />Coal Acceptable <br />to Leasing <br />(Acres)65 <br /> <br />144,790 <br /> <br />320,440 <br /> <br />320,440 <br /> <br />405,230 <br /> <br />371,400 <br />Coal Unsuitable <br />or Closed to <br />Leasing <br />(Acres)66 <br /> <br />1,070 <br />(0.7%) <br /> <br />101,060 <br />(24.0%) <br /> <br />101,060 <br />(24.0%) <br /> <br />16,270 <br />(3.9%) <br /> <br />50,100 <br />(11.9%) <br />(*)Agency Preferred Alternative <br /> <br />For example, with respect to coal mining, the draft EIS considers four alternatives with <br />varying levels of lands open (“acceptable”) to coal leasing. But the range is skewed toward <br />leaving the vast majority of coal-bearing lands open for leasing. As the table above demonstrates, <br />the alternatives leave open to leasing between 76% and 99.3% of all lands with coal resources.67 <br /> <br />Yet even under this lopsided “range” of alternatives, the likely amount of coal produced <br />and burned is identical. Under each alternative, the Draft EIS predicts the same amount of <br />greenhouse gas emissions from coal combustion—27.1 million tons—indicating that none of the <br />alternatives will limit coal production in the planning area in any way. The draft EIS specifically <br />assumes that for each alternative, “[t]he output from the two active mines on BLM-administered <br />land within this coal field is estimated to remain the same as current production, between 9 and <br />11 million tons of coal each year for the next 20 years.”68 <br /> <br />Further, the draft EIS indicates that nearly all of the coal production in the resource area <br />will come from a 40,000 acre area that is almost entirely open to leasing under each alternative: <br /> <br />62 Id. at 4-41 – 4-42 (maximum figures for indirect GHG emissions from coal production); id. at <br />2-409; 4-297 (“coal production is expected to remain the same across all alternatives”). 63 Id. at 4-262, Table 4-31; but see id. at 2-10 (displaying different figures for acreage closed to <br />leasing). 64 Id. 65 Id. at 2-9 – 2-10, Table 2-1. 66 Id. 67 See also id. at 4-274 (“Within the coal potential area, [Alternative B] would be the most <br />restrictive, with 24 percent of the coal potential area unavailable for leasing”). The draft EIS <br />indicates that coal leasing restrictions in the most active coal field – the Somerset – vary between <br />0% and 12% of the lands in that field that “would be unacceptable for further consideration of <br />leasing and development,” meaning that every alternative leaves at least 88% of the most active <br />coal field open for development. Id. at 4-289 – 4-290. 68 Id. at 4-454 (emphasis added).