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

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greenhouse gas emissions in a meaningful and engaging way, connecting the reader and decision-maker to relevant local, regional, and global impacts. Finally,the SCC protocol does not measure the actual incremental impacts of a Project on the biophysical environment in a specific geographic location and does not include all damages or benefits from carbon emissions.The SCC protocol estimates economic damages associated with an increase in CO2 emissions- typically expressed as a one metric ton increase in a single year - and includes, but is not limited to, potential changes in net agricultural productivity, human health, and property damages from increased flood risk over hundreds of years. The estimate is developed by aggregating results "across models, over time, across regions and impact categories, and across 150,000 scenarios" (Rose et al. 2014). The dollar cost figure arrived at based on the SCC calculation represents the value of damages avoided if, ultimately, there is no increase in carbon emissions. But the dollar cost figure is generated in a range and provides little benefit in assisting the authorized officer's decision for Project level analyses. For example, in a recent environmental impact statement,OSMRE estimated that the selected alternative had a cumulative SCC ranging from approximately $4.2 billion to $22.1 billion depending on dollar value and the discount rate used. The cumulative SCC for the no action alternative ranged from $2.0 billion to $10.7 billion (OSMRE 2015). Given the uncertainties associated with assigning a specific and accurate SCC resulting from 22 additional years of operation under the mining plan modification, and that the SCC protocol and similar models were developed to estimate impacts of regulations over long time frames, this analysis quantifies direct and indirect GHG emissions and evaluates these emissions in the context of U.S. and global GHG emission inventories as discussed in Section 2.2.6. To summarize,this analysis does not undertake an analysis of SCC because 1) NEPA does not require cost- benefit analysis and this EA did not conduct an economic cost-benefit analysis; and 2) the full social benefits of coal-fired energy production have not been monetized, and quantifying only the costs of GHG emissions but not the benefits would yield information that is both potentially inaccurate and not useful. The approach taken in this EA qualitatively discusses climate projections and the link to GHGs and quantifies GHG emissions for the various alternatives effectively informs the decision-maker and the public of future climate effects at a variety of scales,whereas the social cost of carbon metric would only provide a monetary value at the global scale. 2.2.5 Mitigation There would not be any mitigation necessary for air and climate resources. 2.2.6 Cumulative Actions and Effects 2.2.6.1 CARMMS Projected Impacts The cumulative impact assessment for air quality considers air emissions from mine operations and coal transport when added to other past, present, and reasonably foreseeable future actions.The cumulative impacts to air quality in the King II Mine area would result primarily from emissions of PM2.5/10 from the Dunn Ranch Area LBA and Mining Plan Modification 28 Technical Resources Report