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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />3 <br /> <br /> In 2009, the Environmental Protection Agency (“EPA”) issued a finding that the changes <br />in our climate caused by elevated concentrations of greenhouse gases in the atmosphere are <br />reasonably anticipated to endanger the public health and welfare of current and future <br />generations. 74 Fed. Reg. 66496 (Dec. 15, 2009). In 2015, EPA acknowledged more recent <br />scientific assessments that “highlight the urgency of addressing the rising concentrations of CO2 <br />in the atmosphere.” 80 Fed. Reg. 64661 (Oct. 23, 2015). <br /> <br /> Earlier this year, the White House Council on Environmental Quality (“CEQ”)—the <br />federal agency tasked with managing the federal government’s implementation of NEPA— <br />recognized the unique nature of climate change and the challenges it imposed on NEPA <br />compliance. On August 1, 2016, CEQ released Final Guidance for Federal Departments and <br />Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in <br />National Environmental Policy Act Reviews (hereafter, “Final Climate Guidance”) (attached as <br />Exhibit 4). The Final Guidance applies to all proposed federal agency actions, “including land <br />and resource management actions.” Id. at 9. Notably, while CEQ’s final guidance post-dates the <br />UFO’s release of the draft EIS, (draft guidance was published December 18, 2014), it is intended <br />to “facilitate compliance with existing NEPA requirements.” Id. at 1. In other words, the Final <br />Guidance is meant to underscore BLM’s existing legal obligations to disclose and consider the <br />foreseeable effects that, for example, coal, oil and gas leasing and development has on climate <br />change. BLM still has ample time to incorporate this Guidance into the Final RMP and EIS. In <br />its Final Guidance, the CEQ recognized that: <br /> <br />Climate change results from the incremental addition of GHG emissions from <br />millions of individual sources, which collectively have a large impact on a global <br />scale. CEQ recognizes that the totality of climate change impacts is not <br />attributable to any single action, but are exacerbated by a series of actions <br />including actions taken pursuant to decisions of the Federal Government. <br />Therefore, a statement that emissions from a proposed Federal action represent <br />only a small fraction of global emissions is essentially a statement about the <br />nature of the climate change challenge, and is not an appropriate basis for <br />deciding whether or to what extent to consider climate change impacts under <br />NEPA. Moreover, these comparisons are also not an appropriate method for <br />characterizing the potential impacts associated with a proposed action and its <br />alternatives and mitigations because this approach does not reveal anything <br />beyond the nature of the climate change challenge itself: the fact that diverse <br />individual sources of emissions each make a relatively small addition to global <br />atmospheric GHG concentrations that collectively have a large impact. <br /> <br />Id. at 10-11. CEQ’s Final Guidance also explains the application of NEPA principles and <br />practices to the analysis of GHG emissions and climate change, including: (1) that agencies <br />quantify a proposed action’s projected direct and indirect GHG emissions, taking into account <br />available data and GHG quantification tools; (2) that agencies use projected GHG emissions as a <br />proxy for assessing potential climate change effects when preparing a NEPA analysis; (3) where <br />GHG emission tools, methodologies, or data inputs are not reasonably available, that agencies <br />include a qualitative analysis in the NEPA document and explain the basis for determining that