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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />4 <br />quantification is not reasonably available; (4) that agencies analyze foreseeable direct, indirect, <br />and cumulative GHG emissions and climate effects; (5) that agencies consider reasonable <br />alternatives and the short- and long-term effect and benefits in the alternatives and mitigation <br />analysis; (6) that agencies consider alternatives that would make the actions and affected <br />communities more resilient to the effects of a changing climate; and (7) that agencies assess the <br />broad-scale effects of GHG emissions and climate change, either to inform programmatic <br />decisions, or at both the programmatic and project-level. See id. at 4-6. <br />A. BLM Failed to Consider National Policy on Climate Change in Agency <br />Decisionmaking. <br /> <br />NEPA requires BLM to consider national policy in its decisionmaking process—a fact <br />expressly recognized by the agency’s purpose and need, DEIS 1-2—yet the DEIS fails to do so <br />with regard to climate change, as detailed above. Remarkably, in a statement detached from the <br />reality of climate change, the science used to understand it, and national policy meant to address <br />it, the UFO’s draft EIS claims: <br /> <br />It may be difficult to discern whether global climate change is already affecting <br />resources in the analysis area of the RMP. It is important to note that projected <br />changes are likely to occur over several decades to a century. Many of the <br />projected changes associated with climate change may not be measurably <br />discernible within the reasonably foreseeable future. Existing climate prediction <br />models are global or continental in scale; therefore, they are not appropriate to <br />estimate potential impacts of climate change on the planning area. The current <br />state of the science involves calculating potential quantities of greenhouse gases <br />that may be added to the atmosphere from a particular activity. However, tools to <br />analyze or predict how global or regional climate systems may be affected by a <br />particular activity or activities within the planning area are not currently available. <br />Assessing the impacts of greenhouse gas emissions on global climate change <br />requires modeling on a global scale which is beyond the scope of this analysis. <br />Potential impacts on climate change are influenced by greenhouse gas emission <br />sources from around the globe and it is not possible to distinguish the impacts on <br />global climate change from greenhouse gas emissions originating from the <br />planning area. <br /> <br />Draft EIS at 4-40. The UFO then concluded: “The projected UFO planning area emissions are a <br />fraction of the EPA’s modeled sources and are shorter in duration, and therefore it is reasonable <br />to conclude that these activities would have no measurable impact on climate, although the <br />emissions would add incrementally to the global GHG loading burden.” Id. <br /> <br />The UFO’s position is reflective of a fundamental disconnect with regard to how our <br />public lands are managed for energy production and national policies to limit GHG emissions. <br />The agency not only fails to take informed action to address climate change, as required by <br />Order 3226 and Order 3289, but signals a deep misunderstanding of basic climate science as well <br />as the “tools and methodologies for quantifying GHG emissions and comparing GHG quantities