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CONSERVATION GROUPS’ COMMENTS UNCOMPAHGRE FIELD OFFICE RMP AND DEIS 97 fossil fuel leases be required to purchase offsets from reputable carbon markets that offset the direct and indirect greenhouse gas emissions from the mining and combustion of fossil fuels from their leases. • BLM should address the full scope of lifecycle emissions through avoidance, minimization, and compensatory mitigation for fossil fuel production, transport and combustion. The premise of compensatory mitigation is to address unavoidable harm. In the case of fossil fuel production, the harm from GHG emissions is primarily attributable to end-use combustion. Nevertheless, BLM should at least address the direct emissions that could be avoided or minimized by, for example, requiring the capture or combustion of methane from coal mines, adopting enforceable mitigation requirements to minimize methane emissions and waste from oil and gas production, etc. • BLM should specify whether compensatory mitigation should be paid on an annual basis or paid up front. Fees collected for compensatory mitigation are often paid in a lump sum at the beginning of a project’s operational life. In the case of climate impacts, however, it may make more sense to consider an annual payment on the basis of production, or an annualized payment schedule based on expected production with corrections on a semi-annual basis. By spreading payments over the life of the project (and tying them to when the impacts actually occur), the system should be both fairer to producers and more true to the spirit of mitigation. • BLM must ensure that compensatory mitigation actions are additional and durable, and last for the duration of impacts. This is an established principle for the Department’s approach to mitigation, but it is particularly important with regard to climate impacts. For example, the Australian Government’s Climate Change Authority found that, “Assessing additionality is a key feature of all baseline and credit schemes. An additionality test assesses whether a project or activity creates ‘additional’ emissions reduction that would not have occurred in the absence of the incentive. The baseline for the project assesses how much emissions have been reduced. Additionality is important to ensure that a baseline and credit scheme does not pay for emissions reductions that would have occurred anyway.”280 IV. The UFO Failed to Take a Hard Look at the Direct, Indirect and Cumulative Impacts of Fossil Fuel Development on Resource Values in the Planning Area. The National Environmental Policy Act (“NEPA”), 42 U.S.C. § 4321 et seq., and its implementing regulations, promulgated by the Council on Environmental Quality (“CEQ”), 40 280 See Australian Government Climate Change Authority, Additionality, http://www.climatechangeauthority.gov.au/reviews/carbon-farming-initiative-study/additionality.