2020-10-27_PERMIT FILE - C1981035 (22)

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According to the U.S. Global Change Research Program (2009), global warming is unequivocal, and the global warming that has occurred over the past 50 years is primarily human caused. Standardized protocols designed to quantify climatic impacts that result from specific emissions, are presently unavailable. Therefore, impact assessment of specific impacts related to anthropogenic activities on global climate change cannot be accurately estimated. Moreover, specific levels of significance have not yet been established by regulatory agencies.Therefore, climate change analysis for this EA within this air quality section is limited to accounting for GHG emissions changes that would contribute incrementally to climate change. Qualitative and quantitative evaluations of potential contributing factors are included where appropriate and practicable. The Office of Natural Resources Revenue, U.S. Department of the Interior data shows that in 2017 total federal (onshore) production of coal in the country stood at approximately 326,073,802 tons. As a whole (federal and non-federal),the U.S. produced approximately 774,609,357 tons of coal in 2017 (U.S. Energy Information Administration). Federal coal made up approximately 42.1 percent of the total 2017 production,and in general has continued to decline along with the total coal production nationally. On an annual basis, the maximum production year for the Proposed Action (800,000 — 1.3 million tons) would represent a range of 0.24—0.40 percent of all federal coal produced nationally and 0.10-0.17 percent of all the coal produced in the U.S. relative to 2017. The total direct and estimated indirect GHG emissions from the maximum projected King II Mine production (based on annual emission estimates) would be approximately 0.28 percent of the total U.S. emissions relative to 2016, and 0.038 percent of the total global GHG burden relative to 2014 on a worst-case year annualized basis. Regardless of the accuracy of emission estimates, predicting the degree of impact any single emitter of GHGs may have on global climate change or on the changes to biotic and abiotic systems that accompany climate change, is not possible at this time. As such, the controversy as to what extent GHG emissions resulting from continued mining may contribute to global climate change, as well as the accompanying changes to natural systems cannot be quantified or predicted. The degree to which any observable changes can, or would be, attributable to the Proposed Action cannot be reasonably stated at this time. Given the cumulative nature of the GHG and climate change issue, and a lack of Project specific impacts, please see the cumulative section below for a general description of anticipated changes and impacts. 2.2.4 Social Cost of Carbon A protocol to estimate what is referenced as the Social Cost of Carbon (SCC) associated with GHG emissions was developed by a federal Interagency Working Group (IWG),to assist agencies in addressing Executive Order (EO) 12866, which requires federal agencies to assess the cost and the benefits of proposed regulations as part of their regulatory impact analyses.The SCC is an estimate of the economic damages associated with an increase in CO2 emissions and is intended to be used as part of a cost-benefit analysis for proposed rules. As explained in the Executive Summary of the 2010 SCC Technical Support Document "the purpose of the [SCC] estimates...is to allow agencies to incorporate the social benefits of reducing CO2 emissions into cost-benefit analyses of regulatory actions that have small, or 'marginal,' impacts on cumulative global emissions." Technical Support Document: Social Cost of Carbon for Regulatory Impact Analysis Under EO 12866 February 2010 (withdrawn by EO13783). While the SCC Dunn Ranch Area LBA and Mining Plan Modification 26 Technical Resources Report