Draft Environmental Impact Statement for Roca Honda Mine

Chapter 3. Affected Environment and Environmental Consequences
released draft guidance on when and how Federal agencies should consider GHG emissions and
climate change in NEPA analyses. The draft guidance includes a presumptive effects threshold of
27,563 tons (25,000 metric tons) of CO2 equivalent emissions from RHR’s proposed project on
an annual basis (CEQ, 2010). The GHG emissions associated with RHR’s proposed action fall
well below the CEQ threshold. These effects would be less than significant.
Table 26. Estimated net CO2 emissions for the proposed Roca Honda Mine
Activity Annual Emissions (tpy) Duration (years) Total Emission (tons)
Mine Development 7,114.9 3.6 25,613.6
Mine Operation 4,696.7 11.5 54,012.1
Mine Reclamation 2,798.9 2.0 5,597.8
Total 17.1 85,223.5
The Forest Service has not determined that GHG emissions are a significant issue for this EIS.
However, the effect of GHG emissions on world climate is an important issue that has received
increasing national and international attention in recent years. The effects of Federal decisions on
GHG emissions has become a factor in NEPA analysis and in Agency operations in the last few
years, depending on the significance of the issue for any project.
On October 5, 2009, President Obama signed Executive Order (E.O.) 13514 (74 Federal Register
52117) to establish an integrated strategy toward sustainability in the Federal Government and to
make reduction of GHG emissions a priority for Federal agencies. Among other provisions, E.O.
13514 requires agencies to “measure, report, and reduce their GHG emissions from direct and
indirect activities.” Section 2 of E.O. 13514 establishes a timeline for Federal agencies to
establish GHG reduction targets and report inventories. The guidance includes the establishment
of a working group to set up reporting protocols and requirements, and is designed to quantify
emissions over which the agency has direct and operational control. This order does not obligate
the Forest Service to inventory the emissions of projects or activities like the applicant’s proposed
Roca Honda Mine, but is referenced here to document the government’s interest in this issue.
The CEQ has developed guidance on the treatment of GHGs in NEPA EISs and released a draft
guidance document for review and comment on February 19, 2010. The guidance is in draft form
and has no direct administrative applicability to the Roca Honda Project or to this EIS for the
following reasons:
• It is in draft form and in the process of evaluation. Comments received during the 90-day
comment period are being evaluated and the guidance is not final and not in effect.
• As proposed, it suggests that a quantitative GHG analysis of agency activities should be
done if a proposed Federal action could reasonably be assumed to cause direct emissions
of 25,000 metric tons (27,500 short tons) of carbon dioxide annually. This would not
apply to the proposed project. This EIS projects operation emissions of approximately
5,000 (short) tons per year of CO2.
• The guidance states that CEQ does not propose to make this guidance applicable to
Federal land and resource management actions.
DEIS for Roca Honda Mine, Cibola National Forest 193