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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />60 <br />available to the agency in a time of turmoil for the coal industry in general and for North Fork <br />mines in particular. Any subsequently-prepared NEPA document must include up-to-date data <br />concerning coal markets, and coal production and coal employment in the area. <br /> <br />The following data and conclusions in the draft EIS are stale given the changes in the <br />local coal industry: <br /> <br />• The draft EIS uses production averages from June 2014 and June 2015, Draft EIS at <br />3-126, although an additional 13 months of data exist demonstrating a steep drop in <br />production since last year (due to Bowie #2’s idling and West Elk’s production drop). <br />The draft also assumes a coal production rate of “9 to 11 million tons per year,” id. at <br />4-255, which is well above the permitted level, let alone the current production rate, <br />of the West Elk mine, the only remaining operating mine in the area. See also id. at 4- <br />289 – 4-290 (“Over the last six years, total yearly production for these underground <br />coal mines has been between 8 and 11 million tons, and is expected to remain about <br />the same”). <br /> <br />• The draft EIS states that projections from the “Energy Information Administration <br />indicate that demand for Somerset’s compliant to super-compliant coal will remain <br />high and will likely continue to provide around 40 percent of Colorado’s coal,” citing <br />2010 data. Id. at 3-126 – 3-127. The draft also cites EIA data indicating coal <br />production economic contributes nearly $400 million annually based on the local <br />production of over 12 million tons of coal from the region. Id. at 3-193 – 3-194. See <br />also BLM, Socioeconomic Baseline Assessment Report (July 2010) at 2-18 <br />(containing same assumptions and conclusions). In 2016, the Somerset field provides <br />less than a third of Colorado’s coal, and production has fallen by two-thirds. Coal’s <br />“economic contribution” as well as taxes and royalties have thus likely dramatically <br />fallen as well. <br /> <br />• The draft EIS alleges that “Locally, coal mining is also an important industry.” Draft <br />EIS at 3-180. See also id. at 3-172 (“Coal mining represents a key component of the <br />economy in this unit”); BLM, Socioeconomic Baseline Assessment Report (July <br />2010) at 6-1 (stating that “[c]oal mining represents a key component of the economy” <br />of the North Fork Valley.”). Given the precipitous drop in coal employment in the last <br />several years, BLM must reevaluate the truth of these statements. <br /> <br />• The draft EIS bases its socioeconomic analysis on assumptions about the level of coal <br />production that appear to be far higher than current levels. <br /> <br />“Approximately 13.8 million tons of coal would be mined in the planning area <br />in Delta, Gunnison, and Montrose Counties in 2012, with approximately 13.1 <br />million tons of that being federal coal (see Table 4-89 [2012 Coal Extraction <br />Levels]). Coal contributions to employment and income from these uses <br />would annually provide approximately 2,018 jobs and over $175 million in <br />labor income, with these figures increasing to 50,350 jobs and over $3.5 <br />billion in labor income over the expected 20 year lifespan of the RMP.”