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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />13 <br />emissions of 4,196 GtCO2,42 with other estimates as high as 7,120 GtCO2.43 <br /> <br />Critically, the United States carbon quota—equivalent to 11% of the global carbon <br />budget needed for a 50% chance of limiting warming to 2°C—allocates approximately 158 <br />GtCO2 to the United States as of 2011.44 By way of comparison, federal and non-federal fossil <br />fuel emissions together would produce between 697 and 1,070 GtCO2.45 Regarding just federal <br />fossil fuel resources, the United States contains enough recoverable coal, oil and gas that, if <br />extracted and burned, would result in as much as 492 GtCO2, far surpassing the entire global <br />carbon budget for a 1.5°C target and nearly eclipsing the 2°C target—to say nothing of the <br />United States ‘share’ of global emissions.46 Unleased federal fossil fuels comprise 91% of these <br />potential emissions, with already leased federal fossil fuels accounting for as much as 43 <br />GtCO2.47 <br /> <br />In 2012, “the GHG emissions resulting from the extraction of fossil fuels from federal <br />lands by private leaseholders totaled approximately 1,344 MMTCO2e.”48 Between 2003 and <br />2014, approximately 25% of all United States and 3-4% of global fossil fuel greenhouse gas <br />emissions are attributable to federal minerals leased and developed by the Department of the <br />Interior.49 Continued leasing and development of federal fossil fuel resources commits the world <br />to ‘extremely dangerous’ warming well beyond the 2°C threshold. As one study put it, “the <br />disparity between what resources and reserves exist and what can be emitted while avoiding a <br />temperature rise greater than the agreed 2°C limit is therefore stark.”50 In short, any new leasing <br />of federal fossil fuel resources is inconsistent with a carbon budget that would seek to avoid <br />catastrophic climate change. <br /> <br />The production horizons for already leased federal fossil fuel resources underscore how <br />unwarranted any additional leasing is, and in turn the reasonableness of the UFO’s consideration <br />of a no-leasing alternative. Comparing these production horizons to dates at which carbon <br />budgets would be exceeded if current emission levels continue: <br /> <br /> <br />42 Michael Raupach, et al., Sharing a quota on cumulative carbon emissions, Nature Climate <br />Change (Sept. 2014) (attached as Exhibit 21). 43 IPCC AR5, Mitigation of Climate Change, Contribution of Working Group III to the Fifth <br />Assessment Report of the Intergovernmental Panel on Climate Change (2014) at Table 7.2 <br />(attached as Exhibit 22). 44 Raupach at 875 (attached as Exhibit 21). 45 Dustin Mulvaney, et al., The Potential Greenhouse Gas Emissions from U.S. Federal Fossil <br />Fuels, EcoShift Consulting (Aug. 2015) at 16 (attached as Exhibit 23). 46 Id. 47 Id. 48 Stratus Consulting, Greenhouse Gas Emissions from Fossil Energy Extracted from Federal <br />Lands and Waters: An Update (Dec. 2014) at 9 (attached as Exhibit 24). 49 See Energy Information Administration, Sales of Fossil Fuels Produced from Federal and <br />Indian Lands, FY 2003 through FY 2014 (July 2015) (attached as Exhibit 25); see also Stratus <br />Consulting (attached as Exhibit 24). 50 McGlade at 188 (attached as Exhibit 20).