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Comments to BLM on Wright Area Coal Lease Extensions in Wyoming

The Bureau of Land Management (BLM) recently published a draft environmental assessment (EA) of coal lease extensions in the Wright Area of Wyoming. BLM’s new analysis reaffirms its 2010 environmental impact statement (EIS) on the same lease extensions despite a court order instructing BLM to correct false assumptions of coal leasing economics. We submitted comments describing how the agency fails to improve its analysis and instead makes the same critical omissions and mistakes.

BLM’s 2010 EIS made an assumption that ignored basic economic principles. It suggested that if the lease extensions had not been granted then other sources of coal would perfectly substitute – so coal combustion and resulting greenhouse gases would remain the same, regardless of leasing. The U.S. Court of Appeals for the Tenth Circuit remanded the 2010 EIS, asking BLM to correct the unsupported assumption of perfect substitution. The agency’s new environmental assessment, however, doubles down on that analysis. Our comments explain the economic mistakes in BLM’s approach. Leasing large tracts of low-cost coal reduces the marginal cost of coal production, which increases the quantity supplied, quantity demanded, and subsequent emissions. As a result, there’s a significant difference in the environmental consequences of the leasing and no-action alternatives. BLM must fix these mistakes and recalculate the economic benefits of the extensions, which were substantially overestimated in its analysis.