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Comments to BLM on Foidel Creek Mine Expansion

A proposed expansion of the Foidel Creek Mine in Colorado would allow Peabody Energy to recover nearly five million additional tons of federal coal, extending the mine’s life by an additional two years. We submitted joint comments that critique the Bureau of Land Management’s (BLM) environmental assessment of the expansion, which miscalculates downstream emissions and fails to monetize the climate damages those emissions will produce.

Based on projections for coal production, the environmental assessment predicts that 108.7 million metric tons of carbon dioxide-equivalent emissions will be emitted directly, indirectly, and downstream over the next two years. Given the reported numbers, however, BLM’s calculation of downstream emissions cannot be reproduced. We ask that BLM recheck its calculations and issue a new draft environmental assessment. We also discuss BLM’s inadequate analysis of emissions impacts. The agency does not apply Social Cost of Greenhouse Gas estimates, despite monetizing other effects of the project, including mine output. BLM must revise its emissions calculations and contextualize their significance through monetized damages.