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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />59 <br /> <br />Coal production and employment in the Somerset coal field have dropped by nearly <br />three-quarters since 2010, with the only operating Somerset field mine likely to produce less than <br />four million tons this year. The Somerset field’s relative share of the state’s coal production has <br />fallen by a third, and its share of employment has dropped by nearly two-thirds. These changes <br />are likely the result of the reduction in coal exports, competition between thermal coal and <br />natural gas, solar, and wind in the utility sector, and regulations limiting haze pollution from coal <br />combustion in national parks and limiting poisonous mercury pollution from power plants. The <br />potential for regulations further internalizing the climate costs of coal (such as the Clean Power <br />Plan) and the increasingly competitive price of cleaner wind and solar make it unlikely that coal <br />markets will mount a long-term recovery. <br /> <br />Falling coal production and employment in the Somerset coal fields demonstrates that <br />draft EIS’s data—most of it from 2010 or before—is stale, and that its assumptions and <br />conclusions are misplaced. For example, much of the draft EIS’s coal data derive from a BLM <br />document entitled “Coal Resource and Development Potential,” dated April 2010. See, e.g., <br />Draft EIS at 4-13 (citing the report to reach conclusions about predicted coal production). That <br />document in turn bases its production estimates in part on 2010 projections from the Energy <br />Information Administration (EIA) which then predicted, among other things, that demand for <br />coal from the Rocky Mountain Region would increase and that “coal will remain the dominant <br />energy source for electricity generation.”198 That prediction has already proven wrong, as natural <br />gas is likely to overtake coal as the dominant source this year.199 EIA’s 2016 report now projects <br />continued coal plant retirements with or without implementation of the Clean Power Plan, and <br />about a 35% decline in coal consumption by 2040 if the CPP is implemented.200 The sharpest <br />declines in coal production under the CPP, will occur in the Western coal region, and EIA <br />estimates coal production in the West will fall even without the CPP.201 While EIA’s Annual <br />Energy Outlook may not be the most reliable predictor of coal production—after all, U.S. coal <br />production this year is already down 20% from 2015 levels—BLM cannot rely on a document <br />that has been revised each year since 2010 and that in 2016 reaches significantly different <br />conclusions than the 2010 report. <br /> <br />Similarly, the draft EIS relies on BLM’s July 2010 “Socioeconomic Baseline Assessment <br />Report,” which, for coal resources, again relies on outdated information (coal data from 2009 <br />and before) that paints an overly rosy picture of the predicted importance and value of coal to the <br />local economy. See Draft EIS at 3-178. Nearly every data point and prediction in this report as it <br />relates to coal production and employment is obsolete given the additional six-plus years of data <br /> 198 BLM, Coal Resource and Development Potential Report (April 2010) at 65 (attached as <br />Exhibit 88). 199 Energy Information Administration, Natural gas expected to surpass coal in mix of fuel used <br />in U.S. power generation in 2016 (Mar. 16, 2016), and available at: <br />http://www.eia.gov/todayinenergy/detail.php?id=25392# (attached as Exhibit 105). 200 Energy Information Administration, Annual Energy Outlook 2016 with projections to 2040 <br />(2016) at MT-17 – MT-18; MT-22, available at: <br />http://www.eia.gov/forecasts/aeo/pdf/0383(2016).pdf. 201 Id. at MT-31.