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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />61 <br /> <br />Draft EIS at 4-468. Similarly optimistic assumptions are contained in the BLM’s <br />2010 Socioeconomic Baseline report. See BLM, Socioeconomic Baseline <br />Assessment Report (July 2010) at 2-6; 2-17. These critical economic assumptions are <br />outdated and inaccurate because it is extremely unlikely that mines in the region will <br />produce 13.2 million tons of coal ever again. The annualized rate for coal production <br />in 2016 based on data through September is under four million tons, and employment <br />has dropped by roughly 80% since 2012. Nearly 1,000 miners worked three active <br />coal mines in the Somerset field in 2012;202 today that number is less than 200. The <br />draft EIS’s conclusions concerning jobs and labor income over the life of the RMP <br />are thus inaccurate, and likely to mislead the public, agency decision-makers, and <br />local governments. <br /> <br />• The draft EIS describes the Bowie #2 mine as “actively producing” although the mine <br />is now idle, and further suggests that the Elk Creek mine may someday resume <br />production. Draft EIS at 3-125. See also id. at 4-11 to 4-12 (making similar <br />statements); id. at 4-258 to 4-259 (same). But Bowie #2 is idle, and Elk Creek is <br />permanently closed. <br /> <br />• The draft EIS also appears to assume that the New Horizon mine will continue to <br />produce coal at its current rate indefinitely, id. at 4-289 – 4-290, although its operator <br />agreed to close it in 2022, six years or fewer into the plan’s life. <br /> <br />• The draft EIS makes assumptions about coal mining rates to address potential impacts <br />to natural resources. For example, the draft EIS predicts an upswing in impacts to <br />some resources because coal mining, among other activities is “becoming more active <br />once again and energy and mineral resources are expected to increase over time, <br />likely resulting in increasing demand for extraction.” Id. at 3-41. While some mineral <br />extraction may be increasing, coal is falling compared to historic levels. Similarly, to <br />address air quality impacts, the draft EIS assumes that “Coal mine production remains <br />unchanged from base year rates with any drop off in existing mine production <br />replaced by production from future mine development in the area.” Id. at 4-28. In the <br />base year of 2011 (see id. at 4-20), Colorado produced 27 million tons of coal, more <br />than twice as much as it is likely to produce this year, and Somerset coal field mines <br />produced 11 million tons, about three times their likely output this year. The draft <br />EIS’s assumption that coal production rates are “unchanged” from 2011 is false. <br /> <br />The fact that the draft EIS relies on stale data is not a mere flyspeck. It is significant <br />because it skews BLM’s analyses of economic values and climate pollution, among many others. <br />Assuming an inflated value for coal production and employment gives a false impression of the <br />relative importance and staying power of this industry as it enters a decline from which there is <br />no foreseeable recovery, given not only competition from cheaper energy sources but the need <br />for the nation – and the world – to end coal combustion if we are to avoid the worst impacts of <br /> <br />202 See DRMS coal production and employment data for 2012, available at: <br />http://mining.state.co.us/SiteCollectionDocuments/2012RevisedDetail2013.pdf.