June 10, 2019
U.S. Department of the Interior
Bureau of Land Management
20 M Street, S.E., Room 4204,
Washington, DC 20003
Submitted online via BLM E-Planning: https://eplanning.blm.gov/epl-front-office/eplanning/comments/commentSubmission.do
Re: Comments on DOI-BLM-WO-WO2100-2019-0001-EA, Lifting the Pause on the Issuance of New Federal Coal Leases for Thermal (Steam) Coal
On behalf of our millions of members and supporters, we urge you to restore the 2016 moratorium on new federal coal leasing until the federal government can complete a thorough programmatic environmental impact review of the federal coal leasing program. Given the massive climate, public health, and pollution costs of the federal coal leasing program, such a review should consider and ultimately implement an end to new coal leasing, a plan to phase out production on existing federal coal leases, and planning for reclamation and just transition for communities affected by federal coal production. It is indefensible to assert that a program singularly responsible for more than ten percent of the nation’s total climate pollution is “insignificant” and undeserving of public scrutiny or meaningful reform.
In 2019, there is no denying that continued expansion of coal mining and combustion is simply incompatible with any reasonable climate mitigation strategy. As you know, a massive and growing body of science, including the Fourth National Climate Assessment and IPCC 2018 Special Report provides overwhelming evidence that climate hazards are more urgent and more severe than previously thought, and that aggressive reductions in emissions within the next decade are essential to avoiding the most devastating climate change harms. The IPCC report concludes that pathways to limit warming to 1.5°C with little or no overshoot require “a rapid phase out of CO2 emissions and deep emissions reductions in other GHGs and climate forcers.”1 Put simply, that means, as scientists have emphasized,2 no new coal.
A decision to lift the leasing moratorium without completing a programmatic environmental review necessarily involves the federal coal leasing program in its entirety. It therefore necessarily
1 Fourth National Climate Assessment (2018), https://nca2018.globalchange.gov/; Intergovernmental Panel on Climate Change, Global warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty (2018) at 2-28.
requires the United States to consider if or how that program should continue in light of its greenhouse gas pollution and the climate crisis. Thus, at precisely the time in which the world must begin rapidly decarbonizing to avoid runaway climate disaster, the BLM has offered a cursory and error-ridden analysis that improperly attempts to excuse lifting of the coal moratorium by dismissing the effects of coal leasing, mining, and combustion as minimal or non-existent. Even more so than in 2016, a leasing moratorium is both justified and necessary to prevent locking in more coal without an opportunity to consider long-overdue reforms to the leasing program.
The 88 billion tons of publicly-owned coal that BLM administers across 570 million acres of public land is unquestionably a globally significant source of greenhouse gas pollution. Mining of federal coal accounts for approximately 40% of all U.S. coal production, and, according to the U.S. Geological Survey, resulted in approximately 735 million metric tons of carbon dioxide combustion emissions in 2014, more than 13 percent of all U.S. carbon dioxide pollution in that year.
The potential carbon emissions from already-leased federal fossil fuel resources would essentially exhaust the remaining U.S. carbon budget consistent with a 1.5°C target. A 2015 analysis estimated that recoverable fossil fuels from U.S. federal lands would release up to 349 to 492 GtCO2eq of pollution if extracted and burned.3 Of that, leased federal fossil fuels would release 30 to 43 GtCO2eq of emissions, of which up to 20 GtCO2eq would result from coal. Carbon emissions from already leased federal fossil fuel resources (30 to 43 GtCO2eq) would, by themselves, essentially exhaust the U.S. carbon budget for a 1.5°C target (25 to 57 GtCO2eq).4
Similarly, a 2016 global analysis found that the pollution from burning the oil, gas, and coal in the world’s currently operating fields and mines would fully exhaust and exceed the carbon budget consistent with staying below 1.5°C.5 The reserves in currently operating oil and gas fields alone, even excluding coal mines, would likely lead to warming beyond 1.5°C.6 A 2019 analysis found that if U.S. coal production is to be phased out over a timeframe consistent with equitably meeting the Paris goals, at least 70 percent of U.S. coal reserves in already-producing mines must stay in the ground. 7 It concluded that the United States must halt permitting new fossil fuel extraction and rapidly phase out existing production to avoid jeopardizing our ability to meet the Paris climate targets and avoid the worst dangers climate disruption impacts.
3 Ecoshift Consulting, et al., The Potential Greenhouse Gas Emissions of U.S. Federal Fossil Fuels, Prepared for Center for Biological Diversity & Friends of the Earth (2015).
4 Robiou du Pont, Yann et al., Equitable mitigation to achieve the Paris Agreement goals, 7 Nature Climate Change 38 (2017), at Supplemental Table 1.
5 Oil Change International, The Sky’s Limit: Why the Paris Climate Goals Require a Managed Decline of Fossil Fuel Production (September 2016), http://priceofoil.org/2016/09/22/the-skys-limit-report/ at Table 3. According to this analysis, the CO2 emissions from developed reserves in existing and under-construction global oil and gas fields and existing coal mines are estimated at 942 Gt CO2, which vastly exceeds the 1.5°C-compatible carbon budget estimated in the 2018 IPCC report on Global Warming of 1.5°C at 420 GtCO2 to 570 GtCO2.
6 The CO2 emissions from developed reserves in currently operating oil and gas fields alone are estimated at 517 Gt CO2, which would likely exhaust the 1.5°C-compatible carbon budget estimated in the 2018 IPCC report on Global Warming of 1.5°C at 420 GtCO2 to 570 GtCO2.
7 Oil Change International, Drilling Toward Disaster: Why U.S. Oil and Gas Expansion Is Incompatible with Climate Limits (January 2019), http://priceofoil.org/drilling-towards-disaster.
In addition to its climate incompatibility, federal coal faces increasingly tenuous economic realities and presents significant harm to public health, land, water, air, and wildlife. As markets shift toward more cost competitive non-coal energy sources, the need to ensure reclamation and facilitate equitable economic transitions in now coal-dependent communities will grow. Thus, BLM should couple a federal coal leasing moratorium with a programmatic environmental impact statement that plans for the inevitable transition away from federal coal production in a way that is orderly and that provides for climate goals, equitable economic transition and mitigation, and environmental justice in coal-dependent and coal-impacted communities.
Failure to heed climate and economic warnings by continuing the federal coal leasing program will lock-in dangerous climate disruption while starving coal-dependent communities of orderly economic transition and mitigation. Now is the time for the United States to act. We urge you to keep in place the 2016 moratorium on new federal coal leasing, undertake a programmatic environmental impact statement to consider necessary reforms to the program, and ultimately to consider and adopt an alternative that ends new coal leasing and plans a course of declining production on producing federal coal leases and a just transition for communities now dependent on and affected by federal coal production.
Taylor McKinnon Nathanial Shoaff
Senior Public Lands Campaigner Senior Attorney
Center for Biological Diversity Sierra Club
1536 Wynkoop St., Ste. 421 Oakland, CA Denver, CO 80202
Timothy Donaghy, Ph.D. Jeremy Nichols Senior Research Specialist Climate and Energy Program Director
Greenpeace USA WildEarth Guardians
Oakland, CA Denver, CO
Nicole Ghio David Turnbull
Senior Fossil Fuel Program Manager Strategic Communications Director
Friends of the Earth US Oil Change International
Berkeley, CA Washington, D.C.
Head of US Campaigns
Save Our Sky Blue Waters
Rev Robert P Hall
Delaware Ecumenical Council on Children and Families
OVEC-Ohio Valley Environmental Coalition
Mary Ellen DeClue
Citizens Against Longwall Mining
Director of Campaigns and Development
Franciscan Action Network
Climate Justice Director
Institute for Policy Studies
New York, NY
Gina B Hardin
Board of Directors
SAFE: So IL Against Fracturing Our Environment
OVEC-Ohio Valley Environmental Coalition
Livelihoods Knowledge Exchange Network
Environmental and Energy Study Institute
Endangered Species Coalition
Buckeye Environmental Network
Rock Mountain Wild
Robert P Hall
Delaware Ecumenical Council
Potomac Valley Audubon Society
Sustainable Energy & Economy Network
Dr. John Talberth
President, Senior Economist
Center for Sustainable Economy
Rae Schnapp, Ph.D.
Indiana Forest Alliance
Senior Policy Analyst
Defenders of Wildlife
Northern Jaguar Project
Kentucky Resources Council, Inc.
Spanish Fork, UT
Western Watersheds Project
Leslie W Glustrom
Clean Energy Action
Montana Environmental Information Center
Valley Watch, Inc
Public Lands Director
High Country Conservation Advocates
Crested Butte, CO
Great Old Broads for Wilderness
Eastern PA Coalition for Abandoned Mine Reclamation (EPCAMR)
Citizens Coal Council
Rainforest Action Network
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Stephen P. Kunz
Schmid & Company, Inc., Consulting Ecologists
Earth Action, Inc.
Lands and Forest Protection Program Manager
San Juan Citizens Alliance
The Lands Council
Richard D Liebert
Citizens for Clean Energy, Inc.
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Climate Hawks Vote
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Rocky Mountain Recreation Initiative