2020-06-24_REVISION - C1981035 ‎(2)‎

• Permit No: C1981035
• IBM Index Class Name: Revision
• Doc Date: 6/24/2020
• Doc Name Note: Environmental Assessment: Dunn Ranch Area
• Doc Name: Proposed Revision Materials
• From: GCC Energy, LLC
• To: DRMS
• Type & Sequence: PR10
• Email Name: JHB
• Email Name: THM
• Media Type: D
• Archive: No

Submission# Organization/Agency Name Commenter Type Comment Comment Response
Greenstone,the former chief economist for the President's Council of Economic Advisers,
ccnNms that it is appropriate and acceptable to calculate the social cost of carbon when
reviewing whether to approve fossil fuel extraction.See Exhibit 35 to previous comments.In
2017,the Proceedings of the National Academy of Sciences of the United States of
America,acknowledged in a peer-reviewed article that the social cost of carbon analysis is
"[t]he most important single economic concept in theeconomics of climate change,"and that
'Yederal regulations with estimated benefits of over$itrillion have used the SCC:'This
article was attached as Exhibit 36 to our previous comments.In sum,the social cost of
carbon provides a useful,valid,and meaningful tool forassessing the climate consequences
of the proposed leasing,and the BUM and OSMRE must utilize this methodology to
a v anal We antl assess the climate impacts of the proposed coal lease.
104 027 Wild Earth Guardians Organizations/ Again,we object to the ELM proposal to move forwartl with analyzing and assessing the See response lines 100 at item 5)and 103.
Non-profits proposed federal coal lease.Issuance of the lease appears wholly contrary to the American
public interest of avoiding the costs of climate charge,of increased air and water pollution,
of increased contamination risks,and of local impacts to public lands and other resources.
In assessing whether the federal coal lease is in the public interest,the BLM must complete
and disclose a thorough comparison of costs and benefits to justify any public interest
tletermination.
105 028 Environmental Defense Fund Organizations/ The following comments focus on the failure to monetize climate damages in the Evans See response lines 100 at item 5)and 103.
Non-rofts MCCurtain coal lease b a lications environmental assessment.
106 028 Environmental Defense Fund Organizations/ Application of the serial cost cf greenhouse gases is not limited to rulemakirgs;NEPA See response lines 100 at item 5)and 103.
Non-profits requires agencies to fully and accurately estimate environmental,public health,and social
welfare differences between alternatives,and the serial cost of greenhouse gases is the
best available tool to com pare the climate im pacts of alternatives
107 028 Environmental Defense Fund Organizations/ Executive Order 13,783 does not bar agencies fron using the samemethodology and See response lines 100 at item 5)and 103
Non-profits inputs applied by the Interagency Woking Group(IWG)to develop its best estimates of
social cost of greenhouse gases and,in fact,by requiring agencies to use best practices,
the Executive Ober woultl point agencies toward the same or higher values of global
climate tlama a calculatetl b the IWG;
108 028 Environmental Defense Fund Organizations/ Although NEPA dos not require a formal cost-benefit analysis,the statute does require a See response lines 100 at item 5)and 103
Non-profits reasonably thorough discussion"antl'necessary contextual information"on real-orld
climate impacts and their significance.The social cost of greenhouse gases provides such
information;
109 028 Environmental Defense Fund Organizations/ BUM monetized a number of other effects ofthe program,including employment and labor See response lines 100 at item 5)and 103
Non-profits income,and must give climate effects the same consideration.When an agency monetizes
a proposed action's potential benefits—as BUM tices here—the potential climate costs must
be treated with proportional rigor.Additionally,simply because not every effect can be
cnetized tices not mean that monetization is not a useful anal !cal tool.
110 028 Environmental Defense Fund Organizations/ BUM inaccurately claims that the range of SCC estimates makes it too difficult to See response lines 100 at item 5)and 103
Non-profits meaningfully compare alternatives;many agencies have deferred to using the 3-percent
entral"discount rate in their SCC analysis in order to weigh the climate effects of
alternatives accurately.
111 028 Environmental Defense Fund Organizations/ BUM inaccurately claims that the SCC is not applicable to a project ofthis duration;the SCC See response lines 100 at item 5)and 103
Non-profits shoultl be applied to annual emissions for every year that emissions from the project occur
in waer to assess the ma nituta of thepro'act's climate im acts.
112 029 Stephen Cantlelaria Individuals 'Verbal Comment'The project woultl do great things for the economy regarding job Comment noted.
creation.
113 029 Stephen Cantlelaria Individuals 'VerbalConment'Eve needs metal and cement and rawcommodities. Comment noted.
114 029 Ste hen Cantlelaria Individuals 'Verbal Comment'Coal expansionneeded here and eve he a Comment noted.
115 029 Stephen Candela
Individuals I've seen the mining intlustry and can say it is encouraging to see that they care about the Comment noted.
erviromment.The indust are gootl stewards of the environment.
116 030 Jim Cantlelaria-Montezuma Elected Officials 'Verbal Comment'The Proposed Action would benefit Montezuma County economically. Comment noted.
C. Commissioner
Jlm Can 117 030 tlelaria-Montezum a Elected Officials 'Verbal Comment'The industry are good stewards. Comment noted.
County Commissioner
118 031 Julia Dengel Individuals 'Verbal Comment'I don't feel there has been enough time to go through the EA and See response Line 7.
supporting documents. ask for an extension to the comment period.
B.
031 Julia Den el Intlivitluals 'Verbal Comment' 1, IIke
if eo le can make comments at the Breen public meet in See res cnsa Line 64.
120 031 Julia Dengel Intlivitluals 'Verbal Comment'I am concerned about lmpact on water.I have a working well created in See response Une 63
the 1940s and
want to make sure 1 can maintain that well.
121 031 Julia Dengel Individuals 'Verbal Comment'I am concern about impact on the environment fron the during of coal. See response Line 65 and Line 73.
We shouldn't be ex antlin the mine at this time no should it be fast-tracked.
122 031 Julia Dengel Individuals 'Verbal Comment'In acts to climate are concerni See response Line 68.
B-15