Full Title: Economic Aanlysis of Proposed Stream Protection Rule
Author(s): Ramboll Environ
Publisher(s): Ramboll Environ
Publication Date: 10/2015
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The purpose of this draft report is to present the results of Ramboll Environ US Corporation’s (hereinafter, “Ramboll Environ”) analysis of the anticipated economic impacts associated with the proposed Stream Protection Rule (hereinafter, “SPR” or “proposed rule”) that was published in draft form by the Office of Surface Mining, Reclamation, and Enforcement (hereinafter, “OSM”) in July, 2015. This report was prepared at the request of the National Mining Association (hereinafter, “NMA”). The analysis contains the following key findings:
- Total number of jobs at risk of loss, including mining and linked sector employment, is between 112,757 and 280,809 (30 percent to 75 percent of current employment levels).
- Direct mining jobs at risk of loss are predicted to range from 40,038 to 77,520, with both surface and underground mining adversely affected.
- The overall decrease in recovery of demonstrated coal reserves is between 27 percent and 64 percent; both surface and underground mines will be significantly impacted.
- The annual value of coal lost to production restriction is between $14 billion and $29 billion.
- Total annual federal and state tax revenue potentially foregone because of lost production is estimated at $3.1 billion to $6.4 billion.
In order to estimate the economic impacts of the proposed SPR, Ramboll Environ evaluated the language of the July 2015 proposed rule and assessed the impact of implementation against current industry statistics and trends. Compliance with the proposed rule was evaluated for 36 current surface and underground mining operations in all regions of the country to determine the impact on access to demonstrated coal reserves. For several of these operations, the proposed rule implies closing operations due to restrictions in access, increased costs, and uncertainty regarding the interpretation of imprecise regulatory language. High and low ranges were calculated to account for various reasonable interpretations of key aspects of the proposed SPR. Respondents were challenged to interpret the rule as best they could, but not to assume a ‘worst case scenario.’