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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />93 <br />Cuddy Mountain v. U.S. Forest Serv., 137 F.3d 1372, 1380 (9th Cir. 1998). An agency’s “broad <br />generalizations and vague references to mitigation measures ... do not constitute the detail as to <br />mitigation measures that would be undertaken, and their effectiveness, that the Forest Service is <br />required to provide.” Id. at 1380-81. See also Northwest Indian Cemetery Protective Association <br />v. Peterson, 795 F.2d 688, 697 (9th Cir. 1986), rev’d on other grounds, 485 U.S. 439 (1988) (“A <br />mere listing of mitigation measures is insufficient to qualify as the reasoned discussion required <br />by NEPA.”); Idaho Sporting Congress v. Thomas, 137 F.3d 1146, 1151 (9th Cir. 1988) <br />(“Without analytical data to support the proposed mitigation measures, we are not persuaded that <br />they amount to anything more than a ‘mere listing’ of good management practices.”). Moreover, <br />in its final decision documents, an agency must “[s]tate whether all practicable means to avoid or <br />minimize environmental harm from the alternative selected have been adopted, and if not, why <br />they were not.” 40 C.F.R. § 1505.2(c). <br />CEQ also recognizes that the consideration of mitigation measures and reasonable <br />alternatives is closely related. For example, CEQ’s guidance on mitigation and monitoring states <br />that “agencies may commit to mitigation measures considered as alternatives in an EA or EIS so <br />as to achieve an environmentally preferable outcome.” Council on Environmental Quality, <br />Appropriate Use of Mitigation and Monitoring and Clarifying the Appropriate Use of Mitigated <br />Findings of No Significant Impact (Jan. 14, 2011) at 1 (hereafter “CEQ Mitigation Guidance”); <br />see also id. at 6-7 (“When a Federal agency identifies a mitigation alternative in an EA or an <br />EIS, it may commit to implement that mitigation to achieve an environmentally-preferable <br />outcome.”). <br />Guidance from CEQ specifically directs agencies to consider where appropriate a variety <br />of mitigation measures for actions that will cause climate pollution, including measures that will <br />capture or use methane emissions: <br />As Federal agencies evaluate potential mitigation of GHG emissions and the <br />interaction of a proposed action with climate change, the agencies should also <br />carefully evaluate the quality of that mitigation to ensure it is additional, <br />verifiable, durable, enforceable, and will be implemented. Agencies should <br />consider the potential for mitigation measures to reduce or mitigate GHG <br />emissions and climate change effects when those measures are reasonable and <br />consistent with achieving the purpose and need for the proposed action. Such <br />mitigation measures could include enhanced energy efficiency, lower GHG- <br />emitting technology, carbon capture, carbon sequestration (e.g., forest, <br />agricultural soils, and coastal habitat restoration), sustainable land management <br />practices, and capturing or beneficially using GHG emissions such as methane.272 <br /> <br /> 272 Final Climate Guidance at 19 (attached as Exhibit 4) (citation omitted).