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Comments on BLM Coal Leasing Environmental Assessment

The Bureau of Land Management (BLM) recently issued an Environmental Assessment (EA) for its decision to lift the Obama administration’s pause on the federal coal leasing program. We submitted comments explaining how the EA provides flawed and incomplete analysis of BLM’s legal authority, alternatives to resuming leasing, and environmental effects.

Our comments describe flaws in the EA, including BLM’s misleading statements about its authority to pause leasing; inadequate analysis of alternatives to resuming leasing; and failure to fully and accurately assess the greenhouse gas (GHG) emissions that would result from resuming the federal coal leasing program. We also explain that BLM must prepare an Environmental Impact Statement to fully evaluate the effects of restarting coal leasing on public lands.

We also submitted joint comments that focus on the EA’s failure to monetize climate damages. BLM should use social cost of greenhouse gases metrics to assess the real-world climate impacts of lifting the moratorium.