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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />101 <br />criteria for the permitting factors in Section III.D., including, for example: what specific <br />magnitude, duration, proximity, conditions, intensity and issues would trigger what specific, <br />corresponding levels of analysis, monitoring, and reporting. More generally, BLM must establish <br />more definitive requirements for monitoring, modeling, permitting and mitigations in Section III <br />of the CARPP. As written, this section of the CARPP only offers analysis and protection of air <br />resources through discretionary means and therefore cannot be relied on to ensure adequate air <br />resource protection. The CARMMS predictions for all alternatives forecast a two- or three-fold <br />increase in criteria pollutants. There is little chance that these significant increases won’t cause <br />or contribute to exceedances of the NAAQS. BLM must address this and plan restrictions in this <br />RMP to avoid these almost certain violations. <br />Section IV of the CARPP includes the adaptive management processes but fails to <br />include enforceable measures that will ensure protection of air resources. Even the enforcement <br />and contingency planning for responding to exceedances of the NAAQS are discretionary and <br />provide no assurances for action. As with Section III, the adaptive management process must <br />incorporate specific, numeric thresholds that trigger further specific actions. Noted below are <br />examples of the nonspecific, noncommittal language included in the CARPP: <br />If during the course of our annual analysis it is determined that the model has not <br />demonstrated a reasonable correlation of predicted impacts (for modeled <br />emissions inventory levels) compared against the actual emissions recorded for a <br />planning area, the BLM will investigate the potential sources of the discrepancy <br />to determine a potential cause, such as meteorological factors (ex: winter time <br />ozone, which cannot be modeled at this time), or fee mineral development (i.e. <br />non-BLM authorized actions). If a probable cause for the discrepancy cannot be <br />established, then the BLM will initiate interagency coordination with our <br />regulatory partners to determine if a new modeling analysis is potentially <br />warranted. <br />CARPP Section IV.C. <br /> <br />BLM should clearly define what it would consider to be “a reasonable correlation” and <br />must specify what would trigger the need for a new modeling analysis. In the provision for <br />evaluating projected future development BLM says it will, “use the projected <br />development/emissions data to determine whether the modeling analysis remains appropriate as <br />a reference for any subsequent project analyses.” CARPP Section IV.E. Again, BLM must <br />establish a threshold that defines what specific measure of difference in the inventory data would <br />trigger a subsequent analysis. Without these specific thresholds that trigger further action, the <br />CARPP cannot function as an adaptive tool to ensure mitigation measures are appropriate to <br />prevent significant impacts to air quality. <br />2. Air Resource Mitigation Measures <br /> <br />In addition to the CARPP, BLM should commit to implementation of specific and <br />enforceable management actions that ensure no significant impacts to air quality and air quality <br />related values—as determined by air quality modeling—in the RMP/EIS. The CARPP should <br />only be used as a tool to improve upon and adapt these management actions as more and