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

Home Browse Search

protocol was created to meet the requirements for regulatory impact analyses during rulemakings,there have been requests by public commenters or project applicants to expand the use of SCC estimates to project-level NEPA analyses. The decision was made not to expand the use of the SCC protocol for this Dunn Ranch Area LBA and Mining Plan Modification for several reasons. First, NEPA does not require a cost-benefit analysis (40 C.F.R. § 1502.23), although NEPA does require consideration of "effects" that include "economic" and "social" effects. 40 CFR 1508.8(b). Regional economic impact analyses describe effects that agency activities may have on economic conditions and local economic activity, generally expressed as projected changes in employment, labor income, and economic output (Watson, Wilson, Thilmany, and Winter 2007). An economic cost-benefit analysis, on the other hand, is an approach used to determine economic efficiency by focusing on changes in social welfare by comparing whether the monetary benefits gained by people from an action/policy are sufficient in order to compensate those made worse off and still achieve net benefits (Watson et al. 2007, Kotchen 2011). A cost-benefit analysis requires the identification and valuation of all the costs and benefits associated with an action/policy in a common monetary measure and is often expressed either as net benefits or as a cost-benefit ratio, which indicates the value of benefits obtained from each dollar of costs (Field 2008). Without a complete monetary cost-benefit analysis, which would include the social benefits of the proposed action to society as a whole and other potential positive benefits, inclusion solely of an SCC cost analysis would be unbalanced, potentially inaccurate, and not useful in facilitating an authorized officer's decision. Any increased economic activity, in terms of revenue, employment, labor income,total value added, and output, that is expected to occur with the proposed action is simply an economic impact, rather than an economic benefit(Watson et al.2007). Based upon their views and values, people may perceive increased economic activity as a 'positive' impact that they desire to have occur; however,that is very distinct from being an 'economic benefit'as defined in economic theory and methodology(Watson et al. 2007, Kotchen 2011). Therefore, it is critical to distinguish that how people may perceive an economic impact is not the same as, nor should be interpreted as, a cost or a benefit as defined in an economic cost-benefit analysis. Though not monetized, climate impacts associated with GHG emissions were analyzed in this project. Research indicates that for difficult environmental issues such as climate change, most people more readily understand when the issue is brought to a scale that is relatable to their everyday life(Dietz 2013); the science and technical aspects are presented in an engaging way such as narratives about the potential implications of the climate impacts(Corner, Lewandowsky, Phillips,and Roberts 2015);and the narratives use examples relevant to the audience that link the local and global scales (National Research Council 2010). In order to more effectively convey the potential climate impacts,the BLM qualitatively discussed potential climate change trends at several scales, for example see Sections 2.2.1.6 and 2.2.6.2 of this appendix. This approach presents the data and information in a manner that follows many of the guidelines for effective climate change communication developed by the National Academy of Sciences (National Research Council 2010),making the information more readily understood by the decision-maker and the general public. This appendix and EA discussed climate trends and projections and quantified Dunn Ranch Area LBA and Mining Plan Modification 27 Technical Resources Report