Less than two weeks before world leaders convene in Paris for an international climate change conference, the Obama administration has again proposed letting coal companies mine in a roadless area of Colorado’s North Fork Valley.

The U.S. Forest Service wants to allow mining despite its own new analysis that reveals the mining could result in a net cost to society of as much as $12 billion. The agency did a social cost of carbon analysis — which includes impacts on agricultural productivity, human health, property damages from increased flood risk, among other things — because a federal judge last year found the government’s original environmental analysis failed to take a “hard look” at the potential contributions to climate change as required by the National Environmental Policy Act. At the time, District Court Judge R. Brooke Jackson stopped the expansion of Arch Coal’s West Elk Mine into the Sunset Roadless Area of the Gunnison National Forest near Paonia. As HCN reported, that ruling was groundbreaking because it was the first time a judge blocked an approval of a coal mine because the government failed to grapple with the mine’s impact on climate change.

The victory helped inspire a group of environmentalists to repeatedly sue the government for its failure to adequately consider climate change in its actions related to federal fossil fuels across the West. Despite the legal onslaught, the Obama administration largely has operated its coal and oil and gas programs as if climate change did not exist. The Forest Service’s new proposal to allow mining in undeveloped areas of the North Fork Valley is the latest example of agencies continuing to defend the status quo.

“This massive give-away to the coal industry undercuts the U.S.’s commitment to reducing climate pollution at a time when the world is looking to America for leadership,” said Earthjustice attorney Ted Zukoski, who represented the groups in federal court. “If there’s any place to keep fossil fuel in the ground, it’s here, where mining for dirty coal will release huge amounts of methane and destroy pristine wildlife habitat next to a wilderness area.”

In its new draft environmental analysis, the Forest Service estimates that if allowed, the mining could contribute anywhere from 13.6 million metric tons of greenhouse gases to 43.2 million metric tons annually. The draft also stated that the mining could last until 2054, depending on the rate of production. In keeping with the judge’s ruling, the analysis also calculates how much additional greenhouse gas emissions would be released nationally if the country opens this area for mining. In the past, the government and industry have argued that if this coal isn’t mined, coal from another mine will just replace it and the climate change impacts will be equivalent. But the agency’s analysis estimates that in fact that’s not the case: 131 million metric tons more climate change pollution could be released than if the mining didn’t happen and other fuels for electricity were used.

Industry representatives and state officials were pleased with the government’s proposal. Mike King, executive director for the Colorado Department of Natural Resources, says reinstating the North Fork Coal Mining Area exception is “fundamental” to achieving the balance between conserving Colorado’s landscapes and providing economic opportunities for local communities.

Stuart Sanderson, president of the Colorado Mining Association, said that even though current market conditions are challenging for coal companies, the Forest Service process to reopen North Fork roadless areas for mining is important. Right now, the demand for Colorado coal is shrinking because of competition from low-priced natural gas, and new state and federal air pollution regulations. But that could change in the future, Sanderson says, and mines need to plan years ahead to acquire leases. Only two years of coal are left to mine under Arch Coal’s current leases, according to the Forest Service analysis. Arch Coal spokeswoman Logan Bonacorsi said the proposal “will extend the life of the mine and help ensure the future viability of important, well-paying jobs in the region.”

But environmental groups blasted the Obama administration for continuing to pursue a federal coal policy that they say is out of sync with President Barack Obama’s climate change objectives.

“With Arch Coal on the verge of bankruptcy, the Obama administration should be helping the North Fork Valley become less reliant on the West Elk mine,” says Jeremy Nichols of WildEarth Guardians.

Nichols says the proposal is all the more glaring given the timing, just before the Paris climate change conference. By contrast, the United Kingdom this week announced plans to close its coal-fired power plants.

“Frankly, this is essentially giving the rest of the world the middle finger,” Nichols said.

Still, mining in Colorado’s roadless areas would be a long ways off. The Forest Service will take public comment for 45 days and hold public sessions in Paonia and Denver early next month. The agency expects to make a final decision next summer. Before any mining could start, the agencies would conduct a separate environmental review, which could take two to four years to complete.