The BLM did not analyze the effects of mining and burning this coal on global climate change because, it claimed, “existing climate prediction models are not at a scale sufficient to estimate potential impacts of climate change within the analysis area.”
Dr. Werner Aeschbach-Hertig, a paleoclimatologist at the University of Heidelberg’s Institute of Environmental Physics, says the BLM reasoning “makes scientifically no sense.”
Dr. Michael Raupach, a top Australian climate researcher who has done influential research on carbon emissions, agreed that “the problem is irrelevant, because single-source impacts are globally shared.” The BLM’s reasoning “leads directly to a tragedy-of-the-commons,” Raupach explained, “in which nobody takes any action and climate change is locked in.
Research examining the social cost of climate change offers guidance on impacts of incremental greenhouse pollution, the scientists said. In the Stern review, the social cost of carbon (SCC) is estimated to lie between $25 and $30 per ton of CO2. More recent valuations estimate the cost between $28 and $893 per ton, rising each decade.
Even with an extremely conservative SCC of $25 per ton, the impact of mining the project’s 100 million metric tons of recoverable coal would be on the order of $7 billion. A proper analysis would take into account that the cost of carbon rises over time, so coal mined in 2040 has higher damages than coal mined now.
The BLM’s statement also contained a skeptical assessment of the impact of burning fossil fuels on the global climate, using qualifiers like “possible”, “potential”, and “may” to question the strength of the scientific conclusion that greenhouse pollution is causing dangerous changes. Dr. Raupach sharply criticized the BLM assessment, saying the language is “far from an accurate reflection of the state of climate science”:
The qualifiers (“possible”, “potential”, “may”) completely understate the confidence of the scientific community in the broad conclusions of climate science and the consequent imperative for action to reduce emissions. The conclusions of the IPCC (2007) Fourth Assessment were essentially that warming is unequivocal and attribution to human influence can be made with very high confidence. Numerous national scientific academies and peak bodies have released their own assessments over the last few years, reinforcing this position. Hence the qualifiers in the question are far from an accurate reflection of the state of climate science.
Dr. Aeschbach-Hertig specifically showed how the BLM statement systematically lowballed the scientific understanding of climate change, as represented by the IPCC in 2007 :
|GHGs have been identified as a possible contributor to the rise in global mean temperatures.
The study of global climate change is complex because there are many factors that may contribute to changes in the earth‘s temperature, including the emission of GHGs […].
|Most of the observed increase in globally averaged temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic greenhouse gas concentrations.
(Very likely is defined as a bigger then 90 % probability of occurrence.)
|Through complex interactions on a regional and global scale, these changes are thought to cause a net warming effect of the atmosphere […].||
The understanding of anthropogenic warming and cooling influences on climate has improved since the Third Assessment Report (TAR), leading to very high confidence that the globally averaged net effect of human activities since 1750 has been one of warming […].
(Very high confidence is defined as a 90 % certainty, i.e. a 9 out of 10 chance of being correct.)
|Ongoing scientific research has identified the potential impacts of anthropogenic (from human activities) GHG emissions and changes in biologic carbon sequestration on the global climate.||
At continental, regional, and ocean basin scales, numerous long-term changes in climate have been observed. These include changes in Arctic temperatures and ice, widespread changes in precipitation amounts, ocean salinity, wind patterns and aspects of extreme weather including droughts, heavy precipitation, heat waves and the intensity of tropical cyclones.
(These changes are unequivocally observed and thus portrayed as facts. Their attribution to anthropogenic climate change is very likely, as the past warming is attributed to the GHG increase, as stated above.)
Dr. Raupach recommended that the policymakers at BLM take a look at “the modern literature on solutions to tragedy-of-the-commons problems in environmental management,” including Dietz T, Ostrom E, Stern PC (2003) The struggle to govern the commons. Science 302:1907-1912 and Pretty J (2003) Social capital and the collective management of resources. Science 302:1912-1914.
It is clear that this draft environmental impact statement needs significant revision before it is finalized.