Laserfiche WebLink
CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />20 <br />the Somerset coal field.69 The only way to produce a range of alternative coal outcomes would <br />be to analyze alternatives that placed significant portions of the Somerset area off-limits to coal <br />mining—which BLM failed to do, in violation of NEPA. Conservation Groups therefore request <br />that BLM evaluate at least one alternative that will result in at least a 50% reduction in coal <br />production in the resource area over the 20-year life of the plan, and another that will eliminate <br />new leasing. See infra at II.C. <br /> <br />The “range” of alternatives regarding coal production is not reasonably broad based on its <br />treatment of other coal producing regions within the Uncompahgre field office area. For <br />example, the vast majority of the Tongue Mesa coal field is left open under each action <br />alternative (92% or more), despite the fact that the draft EIS predicts zero coal will be produced <br />there because the area’s geology makes it “economically unviable to mine in the next 20 <br />years.”70 Similarly, while most of the Grand Mesa coal-field is open to coal leasing under all <br />three action alternatives, coal there is also unlikely to be mined in the next two decades.71 This <br />begs the question: if no coal will be mined in the Tongue Mesa and Grand Mesa coal fields, why <br />did BLM fail to consider an alternative that eliminates coal mining there? <br /> <br />In addition, the draft EIS’s consideration of a skewed range alternatives for coal stands in <br />marked contrast to its treatment of renewable energy. The draft EIS considers alternatives that <br />would open to such development a relatively small acreage (5%), about a third of the acreage, a <br />little over half the acreage, and most the acreage (83%) to wind and solar development.72 The <br />greatest percentage of land open to wind and solar under any alternatives (83%) is still smaller <br />than the least percentage of land open to coal mining in the most active coal field under any <br />alternative (88% of coal-bearing lands), underscoring the lack of range of alternatives concerning <br />coal. <br /> <br />BLM’s alternatives fail to account for current resource conditions, changes in <br />circumstances, and new or revised national-level policy, in particular with regard to climate <br />change. Beyond the agency’s failure to take a meaningful hard look at resource impacts from <br />global warming, as detailed below, BLM failed in its basic obligation to consider all reasonable <br />alternatives, including alternatives that would significantly reduce planning area greenhouse gas <br />emissions, and in particular an alternative that considers not leasing public lands for fossil fuel <br />development. 40 C.F.R. § 1502.14. <br /> <br />The UFO draft RMP and EIS dismisses a number of no-leasing alternatives, citing <br />BLM’s mandate under the Mineral Leasing Act of 1920 (“MLA”) to use the least restrictive <br /> 69 Id. at 4-454 – 4-455. 70 Id. at 4-289 – 4-290 (percentage of Tongue Mesa coal field acceptable for coal leasing); id. at <br />4-454 (economically unviable). 71 Id. at 4-289 – 4-290 (90% or more of Grand Mesa coal field open to mining under all action <br />alternatives); id. at 4-454 – 4-455 (due to the Grand Mesa coal field’s “low coal quality and <br />transportation constraints,” no coal mining is forecast in the area for the next 20 years). 72 See Table 2-3, id. at 2-379. That table shows that the following acres (% of total acres) would <br />be open to solar and wind under the alternatives: Alt. A: 561,200 acres (83%); Alt. B: 34,040 <br />acres (5%); Alt. C: 369,970 acres (55%); Alt. D: acres (34%).