CONSERVATION GROUPS’ COMMENTS
<br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS
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<br />above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C.”7 The
<br />President ratified the Paris Agreement, along with China, on September 3, 2016.8 The President
<br />has also recognized that “the Paris Agreement alone will not solve the climate crisis. Even if we
<br />meet every target embodied in the agreement, we’ll only get to part of where we need to go.”9
<br />
<br />Although national policy and statements addressing climate change have accelerated in
<br />recent years—as they should given the narrowing window of time to take meaningful action—
<br />the federal government’s recognition of climate change is not new. The Secretary of the United
<br />States Department of the Interior stated, in Secretarial Order 3226, Evaluating Climate Change
<br />Impacts in Management Planning (January 19, 2001), that “[t]here is a consensus in the
<br />international community that global climate change is occurring and that it should be addressed
<br />in governmental decision making.” Order 3226 established the responsibility of agencies to
<br />“consider and analyze potential climate change impacts when undertaking long-range planning
<br />exercises, when setting priorities for scientific research and investigations, when developing
<br />multi-year management plans, and/or when making major decisions regarding potential
<br />utilization of resources under the Department’s purview.”
<br />
<br />In a 2007 report entitled Climate Change: Agencies Should Develop Guidance for
<br />Addressing the Effects on Federal Land and Water Resources, the GAO concluded that the
<br />Department of the Interior had not provided specific guidance to implement Secretarial Order
<br />3226, that officials were not even aware of Secretarial Order 3226, and that Secretarial Order
<br />3226 had effectively been ignored. This report led to Secretarial Order 3289, Addressing the
<br />Impacts of Climate Change on America’s Water, Land, and Other Natural and Cultural
<br />Resources (September 14, 2009), which reinstated the provisions of Order 3226, and recognized
<br />that “the realities of climate change require us to change how we manage land, water, fish and
<br />wildlife, and cultural heritage and tribal lands and resources we oversee,” and acknowledged that
<br />the Department of the Interior is “responsible for helping protect the nation from the impacts of
<br />climate change.” A month later, in Executive Order No. 13514, Federal Leadership in
<br />Environmental, Energy, and Economic Performance (Oct. 5, 2009), President Obama called on
<br />all federal agencies to “measure, report, and reduce their greenhouse gas emissions from direct
<br />and indirect activities.” 74 Fed. Reg. 52,117 (Oct. 8, 2009). This directive was followed by
<br />Executive Order No. 13693, Planning for Federal Sustainability in the Next Decade (March 25,
<br />2015), which reaffirmed the federal government’s commitment to reducing GHG emissions. 80
<br />Fed. Reg. 15,871 (March 25, 2015).
<br /> 7 United Nations Framework Convention on Climate Change, Conference of the Parties (Nov 30-
<br />Dec. 11, 2015), Adoption of the Paris Agreement, Art. 2, U.N. Doc. FCCC/CP/2015/L.9 (Dec.
<br />12, 2015), available at: http://unfccc.int/resource/docs/2015/cop21/eng/l09.pdf (“Paris
<br />Agreement”) (attached as Exhibit 2). 8 The White House, President Obama: The United States Formally Enters the Paris Agreement
<br />(Sept. 3, 2016), available at: https://www.whitehouse.gov/blog/2016/09/03/president-obama-
<br />united-states-formally-enters-paris-agreement. 9 The White House, Office of the Press Secretary, Remarks by the President on the Paris
<br />Agreement (Oct. 5, 2016), attached as Exhibit 3, and available at
<br />https://www.whitehouse.gov/the-press-office/2016/10/05/remarks-president-paris-agreement
<br />(last viewed Oct. 26, 2016).
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