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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />14 <br />• Federal crude oil already leased will continue producing for 34 years beyond the <br />1.5°C threshold and 19 years beyond the 2°C threshold; <br />• Federal natural gas already leased will continue producing 23 years beyond the <br />1.5°C threshold and 8 years beyond the 2°C threshold; <br />• Federal coal already leased will continue producing 20 years beyond the 1.5°C <br />threshold and 5 years beyond the 2°C threshold.51 <br /> <br />Opportunities to reduce GHG emissions through the cessation of new leasing and non- <br />renewal of non-producing leases further underscores how unwarranted continued leasing is, and <br />in turn how reasonable the UFO’s consideration of a no-leasing alternative is. <br /> <br />If new leasing and renewal of existing non-producing leases continues, by 2040 it will <br />contribute about two-thirds of expected federal fossil fuel production (forecast based on EIA and <br />other sources).52 On the other hand, if new leasing ceases and existing non-producing leases are <br />not renewed, 40% of forecast coal production could be avoided in 2025 and 74% of coal <br />production could be avoided in 2040. As for oil and gas, 12% of oil production could be avoided <br />in 2025 and 65% could be avoided by 2040 while 6% of natural gas production could be avoided <br />in 2025 and 59% could be avoided by 2040.53 <br /> <br />This avoided production would significantly reduce future U.S. emissions. Cessation of <br />new and renewed leases for federal fossil fuel extraction could reduce CO2 emissions by about <br />100 Mt per year by 2030. Annual emission reductions could become greater than that over time <br />as production declines on existing leases and maintaining or increasing production becomes <br />dependent on yet-to-be issued leases.54 <br /> <br />A comparison with other measures shows that “no leasing” could be a very significant <br />part of U.S. efforts to address climate change. The 100 Mt CO2 emissions savings that could <br />result from no leasing in 2030 compares favorably with EPA standards for light- and medium- <br />vehicles that are expected to yield 200 Mt in CO2 savings in 2030, and with standards for heavy- <br />duty vehicles that are expected to yield 70 Mt in CO2 savings in the same year. The 100 Mt CO2 <br />emissions reduction from leasing restrictions would be greater than either the emission <br />reductions that the EPA expects to achieve through its existing regulation of oil and gas industry <br />emissions or reductions the BLM expects to achieve from its proposed methane waste standards <br />on oil and gas operations on federal land. Clearly, cessation of new and renewed leases could <br />make an important contribution to U.S. climate change mitigation efforts.55 <br /> <br />Also, importantly, avoided production through no new leasing and non-renewal of <br />existing non-producing leases could help avoid further carbon lock-in in terms of investment in <br /> 51 Mulvaney (2016) at 5 (attached as Exhibit 17). 52 Peter Erickson and Michael Lazarus, How Would Phasing Out U.S. Federal Leases for Fossil <br />Fuel Extraction Affect CO2 Emissions and 2°C Goals?, Stockholm Environmental Institute <br />(2016) at 12 (attached as Exhibit 323). 53 Erickson and Lazarus at 16. 54 Id. at 26. 55 Id. at 27.