2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response !�} 99 027 Wild Earth Guardians Organizations/ BLM and OSMRE must analyze and assess the impacts of similar and/or cumulative mining Similar actions are defined in the CEQ regulations at Section 1508.25 as" when viewed with other Non-profits and coal leasing approvals that are also under consideration by the U.S.Department of the reasonably foreseeable or proposed agency actions,have sim ilarities that provide a basis for evaluating their Interior.Under NEPA,an agency must analyze the impacts of"similar"and"cumulative" mental consequences together,such as common timing or geography."Section 3.4.1 of the EA actions in the same NEPA document in order to adequately disclose impacts in an EIS or defines the geographic scope of the cumulative effects area,also known as the cumulative impact analysis provide suRkient justification for a Finding of No Significant Impact in an EA.See 40 C.F.R. area(CIAA),for air quality and climate as La Plata and Montezuma Counties.The EA explains the rationale §§1508.25(a)(2)and(3).The Interior Department and its agencies are currently weighing for the geographic scope.Past,present and reasonably foreseeable actions within those counties are coal decisions like the proposed action,which pose similar and cumulative identified in table 3.1.Further,the EA analyzes air quality and climate impacts of the proposed action impacts in terms of greenhouse gas emissions and climate impacts.These include,but are beyond the 2 counties within the State of Colorado as a whole in the context of the Colorado Air Resources not limited to:•OSMRE's proposal to approve a mining plan modification that would expand Management Modeling Study(CARMMS).CARMMS assesses statewide impacts of projected oil and gas theCaballo coal mine in northeast Wyoming.-BLM and OSMRE's proposal to approve a development(both federal and fee(i.e.,private)out to year 2025 for three development scenarios(low, newoal lease and an expansion of theCoyote Creek coal mine in North Dakota.-BLM's medium,and high),but also included a statewide mining impact assessment.The coal mining operations proposal to approve a lease modification for the Lila Canyon coal mine inUtah OSMRE's located in the State of Colwatlo and evaluated in CARMMS are listed in section 2.2.6.1 of the TRR.OSMRE proposal to approve a mining plan modification that would expand theRosebud coal mine in mine plan actions outside the state are not considered cumulative or similar actions because they do not southeast pp proposal to approve a mining plan modification that would re-have similar geography and are not within the geographic scope of the cumulative effects analysis. approve anexpamion oft a San Juan coal mine in northwest New Mexico.The San Juan coalmine is very near the King II coal mine,located just over the state border in NewMexico.The BLM's proposal to re-approve four massive federal coal leases in northeastWyoming,including the North and South Porcupine leases and North and SouthHighlight coal leases,which would expand the North Antelope-Rochelle and BlackThuntler mines,respectively.-The BLM's proposal to approve a federal coal lease to expand the Antelope mine innortheast Wyoming,The BLM's proposal to approve a federal coal lease to expand the Spring Creek minein southeast Montana.-The BLM's proposal to approve a federal coal lease to expand the Foidel Creek mine in northwest Colorado.These arejust a few pending examples of coal decisions before the Interior Department and its agencies that pose significant climate impacts,particularly in terms of carbon emissions.It is important that OSMRE and BLM analyze the true impacts of mining at lung II consistent with the"hard look"NEPA requires,in order to ensure the agencies make an objective, informed decision cm the proposed coal lease.The preliminary EA tices not acknowledge or Emmention these other coal leasing and mining proposals that are currently before the BLM mention OSMRE.Consequently,the EA's analysis of cumulative impacts isfiawed and contrary to NEPA. 100 027 Wild Earth Guardians Organizations/ In evaluating a proposal that would result in the mining and burning of more federally owned Section 2.2.2 of the TRR Section describes the environmental effects of the CO2 emissions of he Proposed Non-profits coal,OSMRE and BLM must do more than simply quantify carbon dioxide("CO2") Action.Section 3.1.1 of the 2017 Lease Modification EA(BLM 2017)highlights the importance of methane as emi ions that will result from burning coal for cement production.Since 2009,the scientific a greenhouse gas.See response line 88 for additional information on methane. understanding of climate disruption has increased significantly,as has the urgent need for 1)Section 2.2.1.6 of the TRR contains a robust description and discussion of the science of GHGs and their transform ative steps to cut greenhouse gas emissions in the U.S.Greenhouse gas roles in climate change.Section 2.2.6.2 of the TRR describes in detail the latest analyses of the effects of emissions that are particularly important to reduce includ e not only carbon dioxide,but CO2 emissions on climate change an the budget approach and consensus among the scientific community methane as well.Both gases are released as a result of coal mining activities.ln our regarding a target temperature increase that can avoid some of the more dire consequences of projected previous comments,we requested BLM and OSMRE analyze and disclose the following climate change. 2)Section 2.2.1.6 of issues 1)Acknowledge the robust scientific consensus on the need to drastically cut global the TRR discusses climate change in the context of the recent climate reports including the NCA and IPCC CO2 am issions;2)Assess whether the proposed mining and related burning of federal coal reports.The TRR in this section relates the results of the Colorado BLM approach and methodology to areincorsistent with guidance from recent climate reports,including the Fourth National determining the contribution of the Proposed Action to local,regional and global CO2e emissions to the Climate Assessment and reports prepared by the Intergovernmental Panel on Climate context of these reports. 3)Demand and price is driven by market forces,including the cost Change and U.S.Geological Survey;3)Model the market impacts of the proposed and availability of alternate fuels and generation sources.The marginal effect of this supply of coal would be expansion of federal coal mining;4)Recognize the scale of the carbon emission problem speculative,driven by market forces,and considered to be out of scope for this EA.In addition,NEPA tices antl take into account theremaining carbon budget for CO2 emissions from the U.S.;and 5) not require the developin m cis cost-benefit analysis,as is suggested by the comment. Use the social cost cf carbon to analyze and disclose the climate impacts of the proposal 4)Section 2.2.1.6 of the TRR contains a comprehensive description and discussion of a carbon budget and and discuss how other Interior Department proposals relate.The preliminary EA dos not takes into account the remaining carbon budget for CO2 emissions from the U.S. respontl to this request and in fact does not even appear to acknowledge our previous 5)As discussed in section 2.2.4,the SCC protocol estimates the economic damages associated with an ents.To aid the agencies in their review,we therefore restate our prior comments and in in CO2 emissions and is intended to be used as part of a cost-benefit analysis for proposed rules. submit that if the agencies continue to ignore our concerns,any approval of the proposed The tlecision was made not to expand the use of the SCC protocol for this Dunn Ranch Area LEA and coal lease or mining plan will be contrary to NEPA. Mining Plan Modification for several reasons including 1)NEPA does not require a cost-benefit analysis and this EA did not conduct an economic cost-benefit analysis and 2)the full social benefits of coal-fired energy production have not been monetized,and quantifying only the costs of GHG emissions but not the benefits would yield information that is both potentially inaccurate and not useful.The approach taken in this EA qualitatively discusses climate projections and the link to GHGs and quantifies GHG emissions for the various alternatives effectively informs the decision-maker and the public of future climate effects at a vanity of scales,whereas the social cost of carbon metric would only provide a monetary value at the global scale. See section 2.2.4 for more details. B-11