BLM crafting guidance on social cost of carbon — internal memo

By Phil Taylor | 04/15/2015 12:59 PM EDT

The Bureau of Land Management is developing comprehensive guidance on calculating the climate change impacts of mining oil, gas and coal from public lands, according to an internal memo obtained by Greenwire.

The Bureau of Land Management is developing comprehensive guidance on calculating the climate change impacts of mining oil, gas and coal from public lands, according to an internal memo obtained by Greenwire.

The memo, sent this month by Ed Roberson, BLM’s assistant director of resources and planning, says the rapid warming of the planet is primarily caused by humans and that BLM should acknowledge this as it weighs the trade-offs of extracting more carbon-intensive minerals from the earth.

"Anthropogenic climate change is a reality," Roberson wrote in an email to BLM senior managers across the country. "Please ensure that all discussions of climate change in BLM’s [National Environmental Policy Act] documents are consistent with this conclusion."


Roberson’s name does not appear in the document, but the agency confirmed he was the author and that it was sent earlier this month.

The memo says BLM will be issuing "a comprehensive instruction memorandum" addressing climate change and the social cost of carbon in the next few months.

While the impact of that guidance remains unclear, environmentalists said Roberson’s memo is a sign that the agency intends to take better stock of how its land management decisions affect the climate.

"This is the most authoritative statement from BLM on the reality of climate change," said Jeremy Nichols, who oversees climate and energy programs at WildEarth Guardians. "With the Obama administration putting its weight behind climate action, leasing more coal and oil and gas is definitely a liability."

A BLM official today said the memo is consistent with new draft guidance issued last December by the White House Council on Environmental Quality that addressed how federal agencies should consider greenhouse gas emissions and the impacts of climate change when conducting NEPA reviews (E&ENews PM, Dec. 18, 2014).

"That guidance emphasizes that agency analyses should be commensurate with projected greenhouse gas emissions and climate impacts and should employ appropriate qualitative and quantitative analytical methods to ensure useful information is available to the public and the decisionmaking process," the BLM official said.

The memo comes one month after an analysis by the liberal Center for American Progress found that the burning of oil, gas and coal from public lands and waters accounts for more than one-fifth of domestic greenhouse gas emissions (Greenwire, March 19). BLM manages roughly 250 million acres of public lands and is in charge of deciding which publicly owned minerals are leased to private industry and at what cost.

Roberson’s memo may be a response to a decision last September by a federal district judge in Colorado that faulted BLM for failing to account for greenhouse gas emissions when it approved an Arch Coal Inc. mine expansion in a roadless area of the Gunnison National Forest (Greenwire, Sept. 17, 2014).

Environmentalists said that ruling will force BLM and the Forest Service to pay more attention to climate concerns when reviewing coal lease decisions under the National Environmental Policy Act.

Roberson’s memo seems to acknowledge the need for a consistent approach to gauging mining’s impacts on the climate.

In particular, it promises national guidance on how to use a controversial Obama administration tool known as the social cost of carbon (SCC).

The SCC, which the Obama administration first developed in 2010, seeks to estimate the incremental cost of releasing a ton of man-made carbon dioxide into the atmosphere when it comes to property damage, health care costs, lost agricultural output and other factors. The administration sparked a controversy in 2013 when it increased its SCC estimate to $38 per metric ton, up from a 2010 estimate that would have set it at $24.

While it is not a rule itself, the SCC has figured in numerous rulemakings, including U.S. EPA’s Clean Power Plan for existing power plants. Opponents of SCC, namely congressional Republicans, have argued that the administration uses the figure to justify the cost of its rules and claim it is the product of a flawed and nontransparent process.

In the Colorado coal leasing case, Judge R. Brooke Jackson said regulators had to at least explain why they were opting against using the SCC calculation.

According to Roberson’s memo, some BLM field offices have included estimates of the SCC in project-level NEPA documents.

"We are working on additional guidance for the field," he said.

But until then, if BLM field managers want to include the SCC in NEPA decisions, they are to contact BLM’s headquarters in Washington, D.C., "for technical assistance," Roberson wrote.

Nichols, of WildEarth Guardians, said BLM field offices have inconsistently accounted for climate change in their land management decisions. For example, BLM’s Idaho office included a SCC for its May lease sale, finding in its environment assessment in February that burning those minerals could result in $3.7 million annually in carbon costs. But other BLM offices appear to be dismissing the impacts of greenhouse gas emissions from public lands, he said.

According to Roberson’s memo, BLM in August 2014 sent an email to state directors with informal interim guidance on treatment of climate change and the social cost of carbon. That email has not been made public.

BLM in 2011 also circulated draft direction to the field on the use of quantitative greenhouse gas emissions and sequestration estimates and qualitative discussions of climate change impacts in NEPA documents. Roberson’s memo indicates that that direction remains in effect.

Last month, former Interior Deputy Secretary David Hayes and former White House Council of Economic Advisers member James Stock penned an op-ed in The New York Times calling on the Obama administration to boost its scrutiny of federal coal leases, plus add the social cost of burning coal to the price of allowing mining companies to extract the fuel from public land.

Reporters Manuel Quiñones and Jean Chemnick contributed.