2020-06-24_REVISION - C1981035 (2)

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Submission# Organization/Agency Name Commenter Type Comment Comment Response fuels would release 30 to 43 GtCO2eq of emissions,while as yet unleased fossil fuels would emit 319 to 450 GtCO2eq of emissions.Thus,carbon emissions from already leased fossil fuel resources cn federal lands alone(30 to 43 GtCO2eq)would essentially exhaust the U.S.carbon budget for a 1.5°C target(25 to 57 GtCO2eq),if these leased fossil fuels are fully extracted and burned.The potential carbon emissions from unleased fossil fuel resources(319 to 450 GtCO2eq)would exceed the U.S.carbon budget for limiting warming to 1.5°C many times over.40 This does not include the additional carbon emissions that will be emitted from fossil fuels extracted on non-federal lands,estimated up to 500 GtCO2eq if fully extracted and burned.41 This research further establishes that the United States must halt new fossil fuel projects and close existing fields and mines before their reserves are fully extracted to achieve the Paris climate targets and avoid the worst damages from climate change.Furthermore,research that models emissions pathways for limiting rming to 1.5°or 2°C shows that a rapid end to fossil fuel extraction in the United States is critical.Specifically,research indicates that global fossil fuel CO2 emissions must end entirely by mid-century and likely as early as 2045 for a reasonable likelihood of limiting rming to 1.5°or 2°C.This report was attached to our previous comments as Exhibit 20. 42 Due to the small U.S.carbon budget,our country must end fossil fuel CO2 emissions even earlier:between 2025 and 2030 on average for a reasonable chance of staying below 1.n,and between 2040 and 2045 on average for a reasonable chance of staying below 2°C.43 Ending U.S.fossil fuel CO2 emissions between 2025 and 2030,consistent with the Paris climate targets,would require an immediate halt to new production and closing most existing oil and gas fields and coal mines before their reserves are fully extracted.Ending the approval of new fossil fuel production and infrastructure is also critical for preventing 'carbon lock-in,"where approvals and investments made now can lock in decades'worth of fossil fuel extraction that we cannot afford.New approvals for wells,mines,and fossil fuel infrastructure—such as pipelines and marine and rail import and export terminals—require upfront investments that provide financial incentives for companies to continue production for decad es into the future.44 Given the long-lived nature of fossil fuel projects,ending the approval of new fossil fuel projects avoids the lock-in of decades of fossil fuel production antl associated emissions.Reports detailing the need to prevent"lock-in"and to utilize supply-side climate action were attached as Exhibits 21 and 22 to our previous comments. 103 027 Wild Earth Guardians Organizations/ BLM and OSMRE must analyze and assess the climate impacts of mining the proposed As discussed in section 2.2.4,the SCC protocol estimates the economic damages associated with an Non-profits coal lease using the social cost of carbon protocol.The social cost of carbon is a too]that in CO2 emissions and is intended to be used as part of a cost-benefit analysis for proposed rules. discre ated by federal agencies is one method BLM and OSMRE can use to quantify and The decision was made not to expand the use of the SCC protocol for this Dunn Ranch Area USA and lose the harm caused by the proposed project's carbon dioxide emissions.The social Mining Plan Modification for several reasons including 1)NEPA does not require a cost-benefit analysis and cost of carbon provides a metric for estimating the economic damage,in dollars,of each this EA did not conduct an economic cost-benefit analysis and 2)the full social benefits of coal-fired energy mental ton ofcarbon dioxide emitted into the atmosphere.A report detailing this production have not been monetized,and quantifying only the costs of GHG emissions but not the benefits methodology was attached to our previous comments as Exhibit 23.The social cost of would yield information that is both potentially inaccurate and not useful.The approach taken in this EA carbon protocol for assessing climate impacts is a method for'estimate[ing]the economic qualitatively discusses climate projections and the link to GHGs and quantifies GHG emissions for the damages associated with a small increase in carbon dioxide(CO2)emissions, various alternatives effectively informs the decision-maker and the public of future climate effects at a variety conventionally one metric ton,in a given year[and]represents the value of damages of scales,whereas the social cost of carbon metric would only provide a monetary value at the global scale. voided for a small emission reduction(i.e.the benefit of a CO2 reduction)."See Exhibit 24 See section 2.2.4 for more details. to our previous comments.The protocol was developed by an Interagency Working Group ("IWG")consisting of several federal agencies.Although Executive Order 13,783 disbanded the IWG,the entity which developed the social cost of carbon protocol,and withdraw the technical support documents discussed below,the protocol is still"generally accepted in the scientific community."See Exhibit 25 to our previous comments.Indeed,the Trump Administration still uses the SCC protocol despite drastically reducing the damages caused by carbon emissions.Work cn the protocol,began in 2009,with final estimates of carbon costs issued by the IWG in 2010.This report was attached as Exhibit 26 to our previous ents.These estim ates were then revised in 2013,2015,and then in 2016.The 2013, 2015,and 2016 reportswere attached as Exhibits 27,28,and 23,respectively,to our previous comments.Most recently,as an addendum to previous Technical Support Documents regarding the social cost of carbon,the Department of the Interior joined us other agencies in preparing estimates of the social cost of methane and other greenhouse gases.This addendum was attached to our previous comments as Exhibit 29. Depending on the discount rate and the year during which the carbon emissions are produced,the IWG estimates the cost of carbon emissions,and therefore the benefits of reducing carbon emissions,to range from$10 to$212 per metric ton of carbon dioxide.Although often utilized in the context of agency rulemakings,the protocol has been mended for use and has been used in project-level decisions.For instance,the EPA mended that an EIS prepared by the U.S.Department of State for the proposed Keystone XL oil pipeline include"an estimate of the'social cost of carbon'associated with otential increases of GHG emissions."This letter was attached to our previous comments B-13