2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response 101 027 Wild Earth Guardians Organizations/ BLM and OSMRE must acknowledge the findings of recent climate reports,including the Data from the IPCC has been included in the TRR(Section 2.2.6.2"Greenhouse Gases and Climate Non-profits Fourth National Climate Assessment of 2018,as well as two other studies published last Change,Pages 45-50).That section describes the IPCC's projected increase of global mean surface year by the Intergovernmental Panel on Climate Change("IPCC")and the U.S.Geological temperatures and anthropogenic causes of climate change.The TRR goes into detail on the known and Survey.Additionally,information published in January 2019 specifically points out the potential impacts from anthropogenic climate change include,but not limited,to changes in weather patterns, urgent need for land management agencies to say"no"to the fossil fuel industry and for disease transmission,human health,wildfire frequency,and many others.Under current federal laws and elected officials at all guidelines,federal agencies are required to analyze potential fossil fuel extractions and do not have levels to steer the industry towards equitable and otlerly phase-out.The findings of these legislative ability to deny all mining.The ability of this EA to steer elected officials responsible for cent and important climate reports are summarized below. development of future regulations related to the coal industry is outside the stated purpose and need of this proi act. 102 027 Wild Earth Guardians Organizations/ BLM and OSMRE should use carbon budgets to assess climate impacts.One of the BLM and OSMRE evaluate the Proposed Action in the context of carbon budgets both in this EA and in the Non-profits measuring standards available to the agency for analyzing the magnitude and severity of 2017 Lease Modification EA that is incorporated in this EA by reference.Table 2.2-19 of the TRR lays out BLMand OSMRE-related fossil fuel emissions is by applying those emissions to the the carbon budget in percentages by fuel type.US Federal Coal comprises 0.1516%of 2017 emissions and remaining global carbon budget.A"carbon budget"offers a cap on the remaining stock of the carbon budget is calculated from a mean face value of 500Gt.Also,an excerpt from the TRR is as greenhouse gasses that can be emitted while still keeping global average temperature rise follows:"The snapshot data above shows that consuming all of the Federal energy produced in the U.S.in below scientifically-backed warming thresholds—beyond which climate charge impacts 2017(onshore&offshore)would be equivalent to 0.26 percent of the remaining carbon budget,while the may result in severe and irreparable harm to the biosphere and humanity.Utilizing carbon Colorado component of the Federal mineral estate is approximately 0.01 percent of the carbon budget and budgets would offer ELM and OSMRE a methodology for analyzing how the proposed mine just 1.14 percent of total U.S.fossil fuel energy emissions(CO2e)on an annual basis.At the current expansion and the continued coal combustion from the GCC coal lease may affect the production rates shown,total Federal mineral combustion would exhaust the carbon budget in approximately country's ability to meet recognized greenhouse gas emission reduction targets.Scientific 377 years,while Federal minerals in Colorado would do the same in about 8,794 years." earth has estimated the global carbon budget—the cumulative amount of carbon tliozitle that can be emitted—for maintaining a likely chance of meeting the Paris Agreement target of 1.5°C or well below 2°C.According to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change,total cumulative anthropogenic CO2 emissions must remain below 400 GtCO2 from 2011 onward for a 66 percent probability of lira itingwarming to 1 S-C,and below 1,000 GtCO2 from 2011 onward for a 66 percent probability of limiting warming to 2°C above pre-industrial levels.28 The 20181PCC report Global P133 Warming of 1.5°C provided a revised carbon budget for a 66 percent probability of limiting warming to 1.5°C,estimated at 420 GtCO2 and 570 GtCO2 depending on the temperature dataset used,from January 2018 onwards.29 At the current emissions rate of 42 GtCO2 per year,this carbon budget would be expended in just 10 to 14 years, underscoring the urgent need for transformative global action to transition from fossil fuel use to clean energy.Importantly,a 2016 global analysis found that the carbon emissions that would be emitted from burning the oil,gas,and coal in the world's currently operating felds and mines would fully exhaust and exceed the carbon budgets consistent with staying below 1.5°C or 2°C.This analysis was attached to our previous comments as Exhibit 18.31 Further,the reserves in currently operating oil and gas fields alone,even excluding coal would lead to warming beyond 1.5°C.An important conclusion of the analysis is that m lost of the existing oil antl gas fields and coal mines will need to be closed before their are fully extracted in order to limit warming to 1.5°C.32 Some existing feltls and mines ry will need to be closed to limit warming to 2°C.33 In shot,there is no roan in the Arbon budget for new fossil fuel extraction anywhere,including in the United States.34 Additionally,most of the wo ld's existing oil and gas fields and coal mines will need to be closed before their reserves are fully extracted to meet a 1.5°C target.The U.S.has an urgent responsibility to leatl in this transition from fossil fuel production to 100 percent clean energy as a wealthy nation with ample financial resources and technical capabilities,as well as due to our dominant role in driving climate change and its harms.The U.S.is the world largest historic emitter cf greenhouse gas pollution,responsible for 26 percent of cumulative global CO2 emissions since 1870,and is currently the world's second highest emitter on an ual and per capita basis.Research on the U.S:carbon budget and the carbon emissions looked in U.S.fossil fuels similarly establish that the U.S.must halt new fossil fuel production and rapidly phase out existing production to avoid the worst dangers of climate change.Scientifc studies have estimated the U.S.carbon budget consistent with a 1.5°C target at 25 GtCO2eq to 57 GtCO2eq on average,36 depending on the sharing principles used to apportion the global budget across countries.37 The estimated U.S. carbon budget consistent with limiting temperature rise to 2°C—a level of warming well above what the Paris Agreement requires and which would result in devastating harms— ranges from 34 GtCO2 to 123 GtCO2,38 depending on the sharing principles used.Under any scenario,the remaining U.S.carbon budget compatible with the Paris climate targets is extremely small.An analysis of U.S.fossil fuel resources demonstrates that the potential carbon emissions from already leased fossil fuel resources on U.S.federal lands would ssentially exhaust the remaining U.S.carbon budget consistent with the 1.5°C target.This analysis estimated that recoverable fossil fuels on U.S.federal lands would release up to 349 to 492 GtCO2eq of carbon emissions,if fully extracted and burned.This analysis was attached to our revious comm ants as Exhibit 19.39 Of that amount,already leased fossil B-12