United States of America

In Wildearth Guardians, environmental organizations claimed that the Bureau of Land Management (BLM) did not adequately address greenhouse gas emissions associated with coal leases.  In its environmental analysis, the BLM had concluded that there was no appreciable difference between the United States’ total carbon dioxide emissions under the proposed leases and the alternative of not developing the leases (the ‘no action alternative’).  The BLM concluded that opting not to issue these coal mine leases was unlikely to “result in a decrease of U.S.