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2017-05-25_REVISION - C1996083
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2017-05-25_REVISION - C1996083
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Last modified
5/31/2017 6:58:38 AM
Creation date
5/26/2017 8:37:53 AM
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Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
5/25/2017
Doc Name Note
(Citizen Concerns)
Doc Name
Comment
From
Andrew Forkes-Gudmundson
To
DRMS
Type & Sequence
TR112
Email Name
CCW
JRS
Media Type
D
Archive
No
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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />46 <br />Exhibits 79, 80, 81, 82, and 83 provide a visual representation of the potential leasable <br />areas in each alternative for oil and gas that were used to quantify the above emissions totals.132 <br />For coal, the only volume information provided in the draft RMP is in the supporting document <br />entitled the Uncompahgre Field Office’s Colorado Resource Management Plan Revision and <br />Environmental Impact Statement Coal Resource and Development Potential Report. BLM <br />estimates that coal development in the Uncompahgre planning area would occur in an area <br />encompassing about 45,280 acres and containing an estimated 829 million tons of recoverable <br />coal reserves.133 829 million tons of recoverable coal reserves translates into 2.21 GtCO2e, using <br />the same Ecoshift lifecycle emissions calculation tool referenced above. A visual representation <br />of the potential coal leasing acreage for each alternative is provided in exhibits 84, 85, 86, and <br />87.134 It is starkly evident that if BLM were to actually undertake an accurate assessment of <br />potential lifecycle greenhouse gas emissions from each alternative, like we have demonstrated <br />here, the significance of the greenhouse gas emissions impact from future fossil fuel <br />development proposed in the UFO RMP would be undeniable. <br /> <br />Other federal agencies have begun to employ upstream, downstream and lifecycle <br />greenhouse gas emissions analyses for NEPA review of energy-related projects.135 For example, <br /> <br />132 See supra note 128, Center for Biological Diversity Maps and volume estimates. 133 U.S. Bureau of Land Management, Uncompahgre Resource Management Plan Revision and <br />Environmental Impact Statement Final Coal Resource and Development Potential Report at 67 <br />(April 2010) available at <br />http://www.blm.gov/style/medialib/blm/co/field_offices/uncompahgre_field/rmp/rmp_draft_docs <br />_1.Par.93060.File.dat/UFO-FinalCoalRpt_04-15-10_508.pdf (attached as Exhibit 88). 134 Center for Biological Diversity, Maps and volume estimates of future extractible coal mining <br />acreage in the Uncompahgre planning area based on U.S. Bureau of Land Management, <br />Uncompahgre Field Office draft Resource Management Plan and Environmental Impact <br />Statement GIS mapping shapefiles, published June 3, 2016 found at <br />http://www.blm.gov/co/st/en/fo/ufo/uncompahgre_rmp.html. See also id. at 67. 135 U.S. Bureau of Land Management, Final Supplemental Environmental Impact Statement for <br />the Leasing and Underground Mining of the Greens Hollow Federal Coal Lease Tract, UTU- <br />84102, 287 (Feb 2015) (attached as Exhibit 89) (BLM expressly acknowledged that “the burning <br />of the coal is an indirect impact that is a reasonable progression of the mining activity” and <br />quantified emissions from combustion without any disclaimer about other sources of coal. Id at <br />286. In that same EIS, BLM also acknowledged that truck traffic to haul coal would be extended <br />as a result of the proposed lease approval, and this would generate additional emissions); see also <br />U.S. Forest Service, Record of Decision and Final Environmental Impact Statement, Oil and Gas <br />Leasing Analysis, Fishlake National Forest, 169 (Aug 2013) (attached as Exhibit 90) (Table <br />3.12-7: shows GHG emissions from transportation, offsite refining and end use; and total direct <br />and indirect emissions); see also id. at Appendix E/SIR-2 (more detailed calculations of direct <br />and indirect emissions); U.S. Army Corps of Engineers, Final Environmental Impact Statement: <br />Alaska Stand Alone Gas Pipeline, Volume 2 Sec. 5.20-70–71 (Oct. 2012) (attached as Exhibit <br />91) (The Corps, in a 2012 EIS for an intrastate natural gas pipeline in Alaska, estimated <br />downstream emissions from combustion of the natural gas that would be transported, and also <br />discussed the potential for natural gas to displace other, dirtier fuel sources such as coal and oil.); <br />U.S. Department of State, Final Supplemental Environmental Impact Statement for the Keystone
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