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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 90 resilient ecosystems. Although the BLM has recognized the threat of climate change, the agency’s decisionmaking is not reflective of this harm and the agency fails to take the many necessary and meaningful steps to ameliorate the impacts to communities, landscapes, and species. Moreover, CEQ Guidance requires that agencies address the impacts of climate change on the environmental consequences of a proposed action. As the CEQ Guidance recognizes, “[c]limate change can make a resource, ecosystem, human community, or structure more susceptible to many types of impacts and lessen its resilience to other environmental impacts apart from climate change.” Final Climate Guidance at 21. These effects are already occurring and are expected to increase, resulting in shrinking water resources, extreme flooding events, invasion of more combustible non-native plant species, soil erosion, loss of wildlife habitat, and larger, hotter wildfires. These impacts have been catalogued in recent scientific studies by federal agencies, including the National Climate Assessment,270 and highlighted by President Obama. See Exec. Order No. 13,653, § 1. As the CEQ Guidance recognizes, “GHGs already in the atmosphere will continue altering the climate system into the future, even with current or future emissions control efforts.” Final Climate Guidance at 20. In other words, climate change impacts are and will continue to be part of the new normal, and “managing th[o]se risks requires deliberate preparation, close cooperation, and coordinated planning … to improve climate preparedness and resilience; help safeguard our economy, infrastructure, environment, and natural resources; and provide for the continuity of … agency operations, services, and programs.” Exec. Order No. 13,653, § 1. NEPA analyses must account for this reality. While the CEQ Guidance suggests that existing and reasonably foreseeable climate change impacts be considered as part of an agency’s hard look at impacts, the guidance must also account for the fact that climate change effects are and will continue to be a key component of the environmental baseline. Agencies are required under NEPA to “describe the environment of the areas to be affected or created by the alternatives under consideration.” 40 C.F.R. § 1502.15. The affected environment discussion sets the “baseline” for the impacts analysis and comparison of alternatives. As the Ninth Circuit has recognized, “without establishing…baseline conditions…there is simply no way to determine what effect [an action] will have on the environment, and consequently, no way to comply with NEPA.” Half Moon Bay Fisherman’s Marketing Ass’n v. Carlucci, 857 F.2d 505, 510 (9th Cir. 1988) (explaining further that “[t]he concept of a baseline against which to compare predictions of the effects of the proposed action and reasonable alternatives is critical to the NEPA process”). Excluding climate change effects from the environmental baseline ignores the reality that the impacts of proposed actions must be evaluated based on the already deteriorating, climate- impacted state of the resources, ecosystems, human communities, and structures that will be affected. Accordingly, BLM must clarify that existing and reasonably foreseeable climate change impacts as part of the affected environment in the planning area, which then must be assessed as part of the agency’s hard look at impacts, and integrated into each of the alternatives, including the no action alternative. Put differently, simply acknowledging climate impacts as part of the 270 Available at http://nca2014.globalchange.gov/ (attached as Exhibit 6).