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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 92  Persistence of vulnerable conditions and degree of irreversibility of consequences.  Presence of conditions that make societies highly susceptible to cumulative stressors in complex and multiple-interacting systems. In other words, key vulnerabilities are likely to occur where the effects of climate change are large and intense, imminent, long lasting, highly probable, irreversible, and likely to limit the distribution of highly valued systems or system elements. BLM should clarify that understanding and assessing these vulnerabilities, based on existing information and tools,271 is a key component of the affected environment, hard look at impacts, and the design and consideration of alternatives and mitigation measures. H. BLM Must Ensure That Any Subsequently-Prepared NEPA Document Addresses Mitigation for Climate Impacts Consistent with All Relevant Laws and Policies, Including Current Mitigation Guidance. NEPA’s statutory language implicitly charges agencies with mitigating the adverse environmental impacts of their actions. Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 351-52 (1989); Holy Cross Wilderness Fund v. Madigan, 960 F.2d 1515, 1522 (10th Cir. 1992). Mitigation measures are required by NEPA’s implementing regulations. 40 C.F.R. §§ 1502.14(f), 1502.16(h). The CEQ has stated: “All relevant, reasonable mitigation measures that could improve the project are to be identified, even if they are outside the jurisdiction of the lead agency or the cooperation agencies ....” Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations, 46 Fed. Reg. 18026, 18031 (March 23, 1981). According to the CEQ, “[a]ny such measures that are adopted must be explained and committed in the ROD.” Forty Questions, 46 Fed. Reg. at 18036. The Tenth Circuit has held that an agency’s analysis of mitigation measures “must be ‘reasonably complete’ in order to ‘properly evaluate the severity of the adverse effects’ of a proposed project prior to making a final decision.” Colo. Envt’l Coalition v. Dombeck, 185 F.3d 1162, 1173 (10th Cir. 1999) (quoting Robertson, 490 U.S. at 352). Mitigation “must be discussed in sufficient detail to ensure that environmental consequences have been fairly evaluated.” City of Carmel-by-the-Sea v. U.S. Dep’t of Transp., 123 F.3d 1142, 1154 (9th Cir. 1997) (quoting Robertson, 490 U.S. at 353). “[O]mission of a reasonably complete discussion of possible mitigation measures would undermine the ‘action-forcing’ function of NEPA. Without such a discussion, neither the agency nor other interested groups and individuals can properly evaluate the severity of the adverse effects.” Robertson, 490 U.S. at 353. A “perfunctory description,” of mitigation, without “supporting analytical data” analyzing their efficacy, is inadequate to satisfy NEPA’s requirements that an agency take a “hard look” at possible mitigating measures. Neighbors of 271 Where there is scientific uncertainty, agencies must satisfy the requirements of 40 C.F.R. § 1502.22.