Editor's note: The U.S. Bureau of Land Management earlier this month released a draft Environmental Impact Statement examining expansion of the Coal Hollow Mine near Bryce Canyon National Park to more than 3,500 acres. In this guest column, RL Miller, a California-based attorney who keeps watch on public lands issues, questions the wisdom of such an expansion. We welcome other viewpoints on this issue.

The Keystone XL pipeline symbolizes our national debate: a governmental policy to be made that will set policy, for good or bad, for years to come: claimed energy security (access to friendly North American oil) and jobs vs environmental ruin and carbon bomb continuing our addiction to cheap-ish fossil fuels.

Keystone XL is a huge decision to be made at a Presidential level.

However, all across America, similar decisions are being made: fossil fuel production is being expanded with the blessing of the federal government.

Consider Alton Coal.

But first, consider Bryce Canyon National Park.

Bryce Canyon is best known for its hoodoos, but the park is also the last grand sanctuary of natural darkness.

High and dry on the edge of a huge plateau, Bryce has wide open skies; its isolation means no light pollution (light from human activity) and very little air pollution. The park’s Dark Rangers give over 100 astronomy programs each year. Arriving from the west via Las Vegas or Salt Lake City, a Bryce visitor probably passes through Panguitch, an Old West town of 1,600 heavily dependent on tourism - 70 percent of Garfield County’s economy is tourism-based.

What a great place for a coal mine!

Until now, Alton Coal Development, LLC has mined 635 acres of private land in Coal Hollow. It wants to expand on to 3,576 acres of federally owned land, administered by the Bureau of Land Management. The BLM’s draft environmental impact statement, released November 4, considered three alternatives: full-bore production of 2,000,000 tons/year, operating 24 hours a day, 6 days a week; a limited mine on less land with seasonal closures to protect sage grouse and other threatened animals; and no mine at all.

Anyone who thinks the BLM seriously considered all three alternatives needs a reality check. The BLM prefers to expand a strip mine near a national park.

What’s wrong with expanding one strip mine? Everything that’s wrong with Keystone XL, and fossil fuels policy in America, that’s what.

-- dangerous transport: coal trucks traveling 110 miles from mine to a railhead at Cedar City, along U.S. Highway 89,  local roads, and currently unimproved dirt roads, through Panguitch, 24 hours a day, 6 days a week

-- puffed up jobs claims: the mine is said to generate 100 mining jobs and an additional 60 truckers’ jobs. I haven't seen any numbers to rebut this, but I'm skeptical given that strip mining is relatively automated compared to underground mining.

-- impact on federally protected land of great scenic value: the mine will affect Bryce’s clear dark skies, both in creating light pollution (lights will be on at the mine 24 hours a day - the EIS acknowledges a “perceptible increase in nighttime skyglow”) and air pollution

-- corruption of public officials: Alton Coal gave Governor Herbert $10,000 the same day its principals met with him to complain about slow approval of their permit - and the permit was immediately fast-tracked

-- fossil fuel regulatory capture: one alternative presented to the BLM was to develop wind, solar, and other renewable sources, but the BLM refused to consider it as outside the scope of Alton Coal’s request.

-- shipping fossil fuel far away: the coal will fuel the Intermountain Power Plant, which provides 75% of its electricity to the power grid fueling Los Angeles. Meanwhile, Southern Californians are demanding that the Los Angeles Department of Water & Power move beyond coal and phase out reliance on the Intermountain Power Plant by 2020.

-- economics that make no sense: while Alton Coal desires to open this mine, Arch Coal is reducing production at another Utah coal mine due to continuing weakness in coal demand in the region

-- increased carbon emissions: the BLM report estimates that the 2 million tons of coal/year emit 4.8 million tons (4.4 million metric tons) of carbon dioxide/year; for perspective, the United States in 2009 emitted 5,505 million tons of carbon dioxide. On the one hand, the EIS argues that Alton Coal mine is only 0.014% of the world’s 30,377 million tons of carbon dioxide/year. The relative size of any project compared to global emissions is the same argument being used by project proponents all across America, including Keystone XL itself.

Two key differences between Alton Coal and Keystone XL are the size of the project, and the amount of public scrutiny each has received.

Keystone is the XL-sized carbon bomb, while Alton Coal is more of an IED: sufficient to inflict collateral damage, but not enough to get extra-large public scrutiny. The pipeline has become a signature environmental issue of the Obama administration, and a decision whether to approve it will be made by the President. On the other hand, the expansion of Alton Coal is being made by lower-level bureaucrats, without much public comment, and without any national policy weighing renewable energy against the fossil fuels that are slowly poisoning the planet.

Public comments will be taken at various Utah locations, including Cedar City on December 6 and Salt Lake City on December 7.

This column was originally posted to Climate Hawks on Tue Nov 08, 2011, and also republished by Public Lands and Community Spotlight.