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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />95 <br />to cut across jurisdictions and land ownership to “attain the highest mitigation benefit, regardless <br />of land ownership.”274 These key tools from the agency’s guidance should also be emphasized as <br />important aspects of incorporating mitigation into land use planning. <br />BLM is also considering new tools and approaches the agency could use to increase the <br />effectiveness of mitigation on public lands, including layering protective management and <br />designations and exploring creative ways existing authorities could be used for conservation <br />benefits. Effective new mitigation tools and approaches should be integrated into planning as <br />well. <br />Mitigating climate-related impacts includes avoiding and minimizing generation of GHG <br />emissions through management prescriptions and preventing harm to carbon sinks. The CEQ <br />guidance on considering climate change in NEPA analyses provides that agencies should analyze <br />reasonable alternatives that would mitigate both direct and indirect GHG emissions impacts and <br />the cumulative effects of climate change (e.g., enhanced energy efficiency, carbon sequestration, <br />lower GHG-emitting technology).275 BLM must address the quality of mitigation measures as <br />well as ensure they are additional, verifiable, durable, enforceable, and will be implemented. <br />In addition to the legal and policy directions which require mitigation for climate impacts <br />from the Uncompahgre RMP and provide the agency with ample discretion to require mitigation, <br />it is important to underscore that, as a land manager, the federal government in general and BLM <br />in particular are facing huge and rapidly escalating costs to address the impacts caused by fossil- <br />fuel driven climate change. Forest fires, widespread drought, unusual flooding, rising sea levels, <br />spread of invasive species and spread of disease already result in significant costs to the federal <br />government, and each new fossil fuel production project that BLM authorizes through the <br />Uncompahgre plan will worsen these problems and increase the associated costs. Research from <br />the University of Vermont’s Gund Institute for Ecological Economics and The Wilderness <br />Society suggests that total costs in degraded ecosystem services on federal public lands could <br />exceed $14.5 billion annually under a 2-degree Celsius warming scenario.276 These costs are <br />ultimately borne by all American taxpayers, and BLM has a responsibility to recoup these costs <br />when it makes decisions authorizing activities that cause these impacts and associated costs. <br />The Uncompahgre draft RMP alternatives presently contain no mitigation measures <br />aimed at reducing GHG emissions attributable to the plan. The RMP’s failure to contain any <br />GHG mitigation measures (despite the demonstrated harm that continued emissions will have to <br /> <br />274 BLM, Draft – Regional Mitigation, Manual Section 1794 at 1-3 (attached as Exhibit 146). <br />275 Final Climate Guidance at 13, 16 (attached as Exhibit 4). <br />276 See Esposito, Valerie; Phillips, Spencer; Boumans, Roelof; Moulaert, Azur; Boggs, Jennifer. <br />2011. “Climate change and ecosystem services: The contribution of and impacts on federal <br />public lands in the United States.” In: Watson, Alan; Murrieta-Saldivar, Joaquin; McBride, <br />Brooke, comps. Science and stewardship to protect and sustain wilderness values: Ninth World <br />Wilderness Congress symposium; November 6-13, 2009; Merida, Yucatan, Mexico. Proceedings <br />RMRS-P-64. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain <br />Research Station. p. 155-164, available at: http://www.fs.fed.us/rm/pubs/rmrs_p064.pdf (last <br />viewed Oct. 27, 2016) (attached as Exhibit 147).