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Comments to BLM on Resource Management in the Powder River Basin

The Bureau of Land Management (BLM) is considering amending Resource Management Plans for the Miles City and Buffalo field offices in the Powder River Basin. The agency will prepare an environmental impact statement (EIS) for the proposal. We submitted comments at the scoping phase urging BLM to provide analysis that quantifies the external costs of fossil fuel development in the region and evaluates critical land management alternatives.

Mining federal coal in the Powder River Basin accounts for roughly 40 percent of U.S. coal production and 13 percent of U.S. greenhouse gas emissions. Our comments describe how BLM can provide an EIS that adequately assesses the potential impacts of resource development in the region. The agency should monetize the effects of upstream and downstream emissions of fossil fuels open to leasing, using Social Cost of Carbon and Social Cost of Methane estimates. We also encourage BLM to examine certain land management alternatives in the EIS, as well as analyze and disclose energy substitution effects of fossil fuel leasing.