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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />5 <br />across alternative scenarios.” See Final Guidance at 11.10 As stated in Order 3289, BLM must <br />“appl[y] scientific tools to increase understanding of climate change and to coordinate an <br />effective response to its impacts,” and “management decisions made in response to climate <br />change impacts must be informed by [this] science.” Through statements meant to avoid any <br />actual analysis, BLM fails to take a hard look at the climate impacts of fossil fuel leasing and <br />development on public lands in the planning area, as required by NEPA and underscored by the <br />CEQ, as detailed below. Perhaps more importantly, the UFO failed to consider any alternatives <br />that would meaningfully address greenhouse gas emissions and climate change impacts in the <br />planning area—including a no-leasing alternative—and that are reflective of current science and <br />national policy. <br />B. BLM Failed to Consider Recent Climate Science and Carbon Budgeting. <br /> <br />The UFO’s draft EIS frames climate change impacts in precisely the manner warned <br />against by the CEQ,11 stating that “impacts on climate change are influenced by greenhouse gas <br />emission sources from around the globe and it is not possible to distinguish the impacts on global <br />climate change from greenhouse gas emissions originating from the planning area,” concluding <br />that “[a]ssessing the impacts of greenhouse gas emissions … is beyond the scope of this <br />analysis.” Draft EIS at 4-40. Despite the agency’s refusal to provide climate analysis, the UFO <br />does recognize that, “[w]ith respect to global GHG emissions, the following predictions were <br />identified by the EPA for the Mountain West and Great Plains region”—notably contradicting an <br />earlier statement that “[i]t may be difficult to discern whether global climate change is already <br />affecting resources in the analysis area of the RMP.” Draft EIS at 4-40. These predictions <br />include, for example: warmer temperatures with less snowfall; earlier snowmelt impacting <br />ranchers, farmers, recreationalists, and others; more frequent and more severe droughts; impacts <br />to crop and livestock production; forest impacts and increased susceptibility to fire; and that <br />ecosystems will be stressed, impacting wildlife. Draft EIS at 4-40 to 41. <br /> <br />Since the dawn of the industrial revolution a century ago, the average global temperature <br />has risen some 1.6 degrees Fahrenheit. Most climatologists agree that, while the warming to date <br />is already causing environmental problems, another 0.4 degree Fahrenheit rise in temperature, <br />representing a global average atmospheric concentration of carbon dioxide (“CO2”) of 450 parts <br />per million (“ppm”), could set in motion unprecedented changes in global climate and a <br />significant increase in the severity of natural disasters—and could represent the point of no <br />return.12 In August 2016, the atmospheric concentration of CO2 was approximately 402.25 ppm, <br /> <br />10 See also, Final Climate Guidance at 12 n. 28 (linking to quantification tools that “are widely <br />available, and are already in broad use in the Federal and private sectors”). 11 See Final Climate Guidance at 11 (“comparisons [to global or regional emissions] are also not <br />an appropriate method for characterizing the potential impacts associated with a proposed action <br />and its alternatives and mitigations”). 12 See David Johnston, Have We Passed the Point of No Return on Climate Change?, Scientific <br />American (April 2015), available at: http://www.scientificamerican.com/article/have-we-passed- <br />the-point-of-no-return-on-climate-change/.