OAKLAND — California Attorney General Rob Bonta today led a multistate coalition in submitting a comment letter to the Bureau of Land Management (BLM), urging it to consider the full social and environmental costs of the federal coal leasing program. An agency within the U.S. Department of Interior, BLM manages coal resources on public lands across 11 states and leases the right to produce those coal resources to private entities. That coal is transported for both domestic and foreign consumption, with millions of tons of coal being transported each year through California. At present, due to litigation brought by the California Attorney General’s office — along with the attorneys general of Washington, New York, and New Mexico, as well as various environmental organizations — a moratorium is in place on new coal leases. On May 1, 2023, BLM asked for public comment that will help inform its forthcoming environmental impact statement under the National Environmental Policy Act (NEPA) about whether, and to what extent, to resume the program and issue new leases. Today’s comment letter responds to that request.
 
“The last comprehensive environmental review of the federal coal leasing program was completed in 1979, over four decades ago. Renewed consideration of the actual costs and benefits of the program is long overdue,” said Attorney General Bonta. “In 1979, the impacts of climate change were not fully understood. Today, we know that the increase in wildfires, heat waves, and other natural disasters is not a random occurrence, but the direct result of climate change. In addition, millions of tons of coal are transported in open rail cars to ports in Los Angeles, Long Beach, Stockton, and Richmond — areas that are home to communities already disproportionately burdened by environmental pollution. The federal coal leasing program’s significant contributions to these climate and environmental justice issues must be closely scrutinized by BLM before coal leasing can be resumed.”
 
In 2016, the Obama Administration decided to place a moratorium on new coal leases while it initiated a comprehensive environmental review of the program. However, the Trump Administration ceased the Obama Administration’s review and resumed issuing new leases. In response, as mentioned above, the California-led coalition filed a lawsuit in federal district court in Montana, alleging that BLM’s decision to restart the federal coal leasing program without any environmental review violated NEPA. The court agreed and reinstated the moratorium on new leases. In 2021, Interior Secretary Deb Haaland separately initiated a programmatic review of the coal leasing program that remains pending. Attorney General Bonta also submitted public comment on that review.
 
In their comment letter, the California-led coalition again urges BLM to fully consider all direct, indirect, and cumulative impacts of issuing new coal leases under the program, including:
 
Climate Change: Federal coal production, transport, and consumption are estimated to account for approximately 11 percent of total U.S. greenhouse gas emissions (and that does not account for the additional emissions attributable to domestic coal consumed abroad). As the western U.S. battles record-breaking wildfires, unprecedented drought, and extreme heat, BLM must consider the heavy toll of climate change on the states’ economies, residents, and natural resources. In 2020 alone, there were 22 weather events that each cost the economy at least $1 billion, the most recorded since the National Oceanic and Atmospheric Administration began tracking the cost of these disasters. The average number of annual billion-dollar events since 1980 is eight; the average number since 2018 is more than double, at 18. While states like California have long been at the forefront of the fight against climate change, state programs alone are not enough. Reducing coal production and consumption (domestically and abroad) is one of the lowest-hanging fruits in state — and federal — efforts to reduce greenhouse gas emissions.
 
Environmental Justice: All communities should be able to breathe clean air, drink clean water, and live in a safe and healthy environment. Too often, however, low-income communities, communities of color, and tribal and indigenous communities lack access to these necessities. The federal coal leasing program adds to their environmental burdens, both in the communities surrounding coal mines and elsewhere. In California, millions of tons of coal are transported each year in open rail cars to ports in Los Angeles, Long Beach, Stockton, and Richmond — through and into communities that are already disproportionately impacted by environmental pollution and that suffer the resulting health consequences. For example, particulate matter emissions from the storage and handling of coal can cause or contribute to a wide variety of serious health problems, including asthma, bronchitis, cardiovascular diseases, and cancer. While numerous environmental impacts of the federal coal leasing program remain to be addressed — including impacts to water quality, air quality, and wildlife — the coalition specifically urges BLM to consider the environmental justice impacts from the export of federal coal.
 
Further, with respect to existing leases, the attorneys general request that BLM incorporate the social cost of carbon and social cost of methane into the royalty rate for leases as they come up for 10-year renewals; and deny all pending and future requests for royalty relief as improper fossil fuel subsidies.
 
In sending the comment letter, Attorney General Bonta is joined by the attorneys general of Maryland, New Jersey, New Mexico, Oregon, and Washington. 
 
A copy of the comment letter can be found here.