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Comments on Forest Service’s West Elk Mine Environmental Impact Statement

In 2014, the U.S. District Court of Colorado ruled that the Forest Service’s plan to expand leases for the West Elk coal mine had “inadequately disclosed the effects of greenhouse gas emission,” in particular by failing to monetize climate damages using the social cost of carbon and social cost of methane. In its new Environmental Impact Statement (EIS) for the expansion, the Forest Service again fails to monetize climate damages in its cost-benefit analysis. It claims that these methods are not appropriate at the project level, that the court ruling was issued prior to an executive order withdrawing federal guidance on these estimates and thus no longer applies, and that the EIS did not selectively exclude climate impacts because it also does not monetize other benefits or costs.

We argue that these justifications are inadequate in our joint comments with the Environmental Defense Fund, the Natural Resources Defense Council, the Sierra Club, and the Union of Concerned Scientists. Agencies must monetize important greenhouse gas effects when their decisions are grounded in cost-benefit analysis, and the Forest Service triggered this requirement in listing how much the expansion would increase federal revenue. Agencies must continue to use the best available data and methodologies to estimate the social cost of greenhouse gases, and the federal social cost of greenhouse gases continue to reflect the best available data and methodological choices. The agency must analyze the potential increase in demand for coal and the resulting emissions from the proposed action, which the Forest Service claims could “represent 1.67% of all federal coal produced nationally” and is thus unlikely to be minimal.