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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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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
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No
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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />65 <br />[and] social” impacts of the proposed action. 40 C.F.R. § 1508.8(b). Simple calculations <br />applying the SCC to GHG emissions from this project offer a straightforward comparative <br />basis for analyzing impacts, and identifying very significant costs.216 <br /> <br /> Notably, according to the IPCC, the 20-year GWP for methane—which is not only the <br />planning lifespan of the RMP, but the relevant timeframe for consideration if we are to stem the <br />worst of climate change—is 87.217 Here, BLM’s reliance on the outdated 1996 100-year horizon <br />of 21 significantly underestimates the magnitude of emissions. DEIS 4-38. Accordingly, if the <br />updated GWP of 87 for methane is applied to 135,082 tons of methane emissions per year under <br />BLM’s Preferred Alternative D, direct emissions from the activities increase dramatically from <br />2,836,722 MTCO2e to 11,752,134 MTCO2e. When added to emissions of carbon dioxide and <br />nitrous oxide, true direct planning area emissions increase to 12.03 MMTCO2e (up from 3.11 <br />MMTCO2e), or a social cost of carbon of $505,186,962 when applying a median value of $42. <br /> <br />Critically, however, these costs only relate to direct planning area emissions. BLM also <br />includes, in table 4-11, annual indirect emissions from BLM actions resulting from the <br />combustion of coal, oil and gas, which together total 27,366,562 MMTCO2e each year. When <br />combined with direct emissions, this totals 39,394,823 MMTCO2e of annual BLM related <br />emissions, or a social cost of $1,654,582,566 per year from BLM related actions. <br /> <br />Instead of considering these costs, the agency remarkably concludes that “it is not <br />possible to distinguish the impacts on global climate change from greenhouse gas emissions <br />originating from the planning area” and later that “[t]he projected UFO planning area emissions <br />are a fraction of the EPA’s modeled source and are shorter in duration, and therefore it is <br />reasonable to conclude that these activities would have no measurable impact on the climate.” <br />DEIS at 4 -40. <br /> <br />As noted by Judge Jackson, the SCC protocol provides a tool to quantify the costs of <br />these emissions. See High Country Conservation Advocates, 52 F.Supp.3d at 1190. By failing to <br />consider the costs of GHG emissions from the Proposed Action, the agency’s analysis effectively <br />assumes a price of carbon that is $0. See id. at 21 (holding that although there is a “wide range of <br />estimates about the social cost of GHG emissions[,] neither the BLM’s economist nor anyone <br />else in the record appears to suggest the cost is as low as $0 per unit. Yet by deciding not to <br />quantify the costs as all, the agencies effectively zeroed out the cost in its quantitative analysis.”). <br />The agency’s failure to consider the SCC is arbitrary and capricious, and ignores the explicit <br />directive of EO 12866. <br /> <br />Further, BLM’s failure to undertake a social cost of carbon analysis here is also arbitrary <br /> <br />216 It is important to note that, although the 2010 IWG SCC protocol did not address methane <br />impacts, the 2013 IWG Technical Update explicitly addresses methane impacts. Thus, it is <br />appropriate to calculate a SCC outcome that takes into account the full CO2e emissions <br />associated with the proposed leasing. 217 See INTERGOVERNMENTAL PANEL ON CLIMATE CHANGE, Working Group I Contribution to the <br />IPCC Fifth Assessment Report Climate Change 2013: The Physical Science Basis, at 8-58 (Table <br />8.7) (Sept. 2013) (attached as Exhibit 113). <br />
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