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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />96 <br />the Uncompahgre area, BLM lands generally, and across the globe), or to even consider any such <br />mitigation measures violates NEPA. <br />2. BLM Should Adopt a Mitigation Strategy as Part of the <br />Uncompahgre Field Office RMP to Address Unavoidable Climate <br />Change Impacts. <br /> <br />To comply with NEPA’s mandates, and BLM policy, concerning mitigation, BLM should <br />require compensatory mitigation to offset the unavoidable direct and indirect climate change <br />impacts of the Uncompahgre RMP. Such mitigation would contain several key features: <br />• BLM should quantify and offset emissions through specific compensatory <br />mitigation actions <br />Quantifying climate change impacts is becoming increasingly more practical, and the <br />science connecting impacts to temperature changes increasingly more precise. Compensatory <br />mitigation actions can be directed at enhancing the adaptive capacity of human and natural <br />communities in the affected landscape to improve their health and resilience in the face of <br />expected change. Offsetting actions should include investments in land protection to ensure that <br />the UFO’s ecological systems have the space and conditions to adapt. <br />Significant opportunity exists to offset GHG emissions. EPA has repeatedly urged land <br />management agencies to assess carbon offsets in Environmental Assessments and EISs as a way <br />to reduce the climate change impacts of agency actions. For example, EPA specifically <br />recommended that the Forest Service’s Lease Modifications EIS for the West Elk Mine (on <br />which the Uncompahgre Field Office was a cooperating agency) “acknowledge that revenues for <br />carbon credits are available via several existing markets.”277 Similarly, EPA has recommended <br />that a Forest Service NEPA analysis of a forest health project “discuss reasonable alternatives <br />and/or potential means to mitigate or offset the GHG emissions from the action.”278 Numerous <br />state agencies already use offsets to control GHG emissions.279 Offsets can include participation <br />in third-party offset markets or renewable energy credits. <br />In any subsequently prepared NEPA document, the BLM should consider mitigation <br />measures that offset the direct and indirect carbon emissions attributable to the draft plan <br />alternatives – 27 million tons. Specifically, BLM should consider requiring that purchasers of <br /> 277 EPA July 2012 Comment Letter at 5 (attached as Exhibit 148) (identifying four U.S. carbon <br />exchanges creating a market for carbon credits). <br />278 Letter of L. Svoboda, EPA, to T. Malecek, USFS, at 8 (Oct. 27, 2010) (attached as Exhibit <br />149). <br />279 See, e.g., Settlement Agreement, ConocoPhillips and California (Sept. 10, 2007) (California <br />agency requiring offsets as a condition of approving a project) (attached as Exhibit 150); Minn. <br />Stat. § 216H.03 subd. 4(b) (Minnesota law requiring offsets for certain new coal-fired power <br />plants); Me. Rev. Stat. Ann. tit. 38, § 580-B(4)(c) (Maine law establishing greenhouse gas <br />initiative that includes the use of carbon offsets).