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Comments to BLM on Coal Management Plans

In response to a recent court order, the Bureau of Land Management issued a Notice of Intent to amend two resource management plans involving coal leasing: the Buffalo Field Office and Miles City Field Office resource management plans. Our comment letter offers guidance to BLM on how it should consider the climate impacts of different leasing alternatives, as required by the court’s order. The comments discourage the comparison of project emissions to global or national totals, support the use of the social cost of greenhouse gases, and discuss best practices for the proper use of substitution analysis.