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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />94 <br />1. Consistent with the Mitigation Hierarchy, BLM Must Avoid, <br />Minimize and Offset Impacts from Fossil Fuels Made Available by the <br />Uncompahgre RMP, Including Climate Change-Related Impacts. <br /> <br />BLM has significant obligations and authority related to mitigation for all unavoidable <br />impacts. Secretarial Order 3330 requires the development of a landscape-scale mitigation policy <br />for the Department of the Interior, which is appropriately done at the field office plan level. <br />Section 4(c) of Secretarial Order 3330 directs the Department of the Interior’s Energy and <br />Climate Change Task Force to: <br />[I]dentify any new policies or practices, revisions to existing policies or practices, <br />or regulatory or other changes that could be implemented to incorporate <br />landscape-scale planning into mitigation-related decisions… The Task Force will <br />also determine what steps can and should be taken to ensure that mitigation <br />opportunities are identified as early in the permitting process as possible, such as <br />at the scoping or pre-application stage, to maximize predictability and <br />transparency in the review and permitting process. <br />In a report to the Secretary of the Interior, the Energy and Climate Change Task Force <br />laid out a landscape approach to mitigation.273 This approach contained the following steps: <br />1. Identifying key landscape attributes, and the conditions, trends and baselines that <br />characterize these attributes; <br />2. Developing landscape-scale goals and strategies; <br />3. Developing efficient and effective compensatory mitigation programs for impacts that <br />cannot be avoided or minimized; and <br />4. Monitoring and evaluating progress and making adjustments, as necessary, to ensure <br />that mitigation is effective despite changing conditions. <br />BLM’s current guidance (IM No. 2013-142 and Draft Manual Section 1794) states that as <br />part of approving specific land uses, mitigation implementation may be “within (onsite) or <br />outside of the area of impact.” The manual emphasizes that onsite mitigation is always the first <br />choice, including a “mitigation priority order,” then discusses options to provide offsite <br />mitigation by replacing or providing similar or substitute resources or values through <br />“restoration, enhancement, creation, or preservation.” <br />BLM’s policy emphasizes that it is designed to “shift the BLM’s mitigation focus from a <br />permit-by-permit perspective to a proactive regional-scale mitigation planning perspective” and <br /> 273 Clement, J.P. et al., A strategy for improving the mitigation policies and practices of the <br />Department of the Interior. A report to the Secretary of the Interior from the Energy and Climate <br />Change Task Force (April 2014), available at: <br />https://www.doi.gov/sites/doi.gov/files/migrated/news/upload/Mitigation-Report-to-the- <br />Secretary_FINAL_04_08_14.pdf (attached as Exhibit 145).