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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />68 <br /> <br />Nor can the agency tout the benefits of coal, oil and gas development without similarly <br />disclosing the costs. See 40 C.F.R. § 1502.23. For example, BLM identifies “tax impact from <br />coal extraction in the planning area” as a benefit, with revenues “associated with the sales and <br />income earned from extraction and transportation of coal.” DEIS at 4-465. Although not <br />quantified in the same way, BLM also assumes that “increased production of oil and gas on <br />BLM-administered lands would result in a comparable increase in contributions to local counties <br />and communities.” Id. Accordingly, BLM relies on figures in Table 4-90 (Baseline Regional <br />Economic Impacts for Coal), to suggest a substantial net economic benefit, including $556 <br />million in annual output and $175 million in labor income. DEIS at 4-469. Setting aside that this <br />economic data is based on wildly optimistic assumptions on future coal production and <br />employment for 2,518 people—with a current reality of coal mines being shut down and present <br />employment of around 250 people—this type of misleading and one-sided analysis is expressly <br />forbidden under NEPA. See Hughes River Watershed Conservancy v. Glickman, 81 F.3d 437, <br />446-47 (4th Cir. 1996) (“it is essential that the EIS not be based on misleading economic <br />assumptions); Sierra Club v. Sigler, 695 F.2d 957, 979 (5th Cir. 1983) (agency choosing to <br />“trumpet” an action’s benefits has a duty to disclose its costs). Moreover, even assuming BLM’s <br />optimistic economic benefits, it still pales when compared to the social costs of planning area <br />greenhouse gas emissions, totaling $1,654,582,566 per year. <br /> 2. Social Cost of Methane Protocol <br /> <br />In August 2016, the Interagency Working Group (“IWG”) provided an update to the <br />social cost of carbon technical support document,221 and, for the first time, adopted a similar <br />methodology for evaluating the climate impact of each additional ton of methane and nitrogen <br />oxide emissions.222 Given its recent endorsement by the IWG, BLM should use the social cost <br />of methane to quantify the expected climate damage caused by the extraction and combustion of <br />coal, oil, and natural gas extracted under BLM’s draft plan for the Uncompahgre planning area. <br />Similar to the social cost of carbon, the social cost of methane provides a standard methodology <br />that allows state and federal agencies to quantify the social benefits of reducing methane <br />emissions through actions that have comparatively small impacts on cumulative global emission <br />levels. The social cost of methane is intended to “offer a method for improving the analyses of <br /> 221 Interagency Working Group, Technical Support Document: Technical Update of the Social <br />Cost of Carbon for Regulatory Impact Analysis Under Executive Order 12866 (August 2016), <br />available at <br />https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc_tsd_final_clean_8_26_16.pdf <br />(last visited November 1, 2016) (attached as Exhibit 324). The August 2016 update added some <br />clarifying information around uncertainties in the modeling that supports the social cost of <br />carbon, but did not adjust the damages values (the costs) published in the 2015 update. 222 Interagency Working Group, Addendum to Technical Support Document on Social Cost of <br />Carbon for Regulatory Impact Analysis under Executive Order 12866: Application of the <br />Methodology to Estimate the Social Cost of Methane and the Social Cost of Nitrous Oxide <br />(August 2016), available at <br />https://www.whitehouse.gov/sites/default/files/omb/inforeg/august_2016_sc_ch4_sc_n2o_adden <br />dum_final_8_26_16.pdf (last visited October 30, 2016) (attached as Exhibit 325.